INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 We make Indiana a cleaner, healthier place to live. 

Mitchell E. Daniels, Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204 

 (317) 232-8603 

Thomas W. Easterly (800) 451-6027 

Commissioner www.IN.gov/idem 

Page 1 of 2 

FNTV-PMOD.dot 1/10/05 

 Recycled Paper An Equal Opportunity Employer Please Recycle 

 

TO: Interested Parties / Applicant 

DATE: July 7, 2006 

RE: Lehigh Cement Company / 093-21975-00002 

FROM: Nisha Sizemore

 Chief, Permits Branch 

 Office of Air Quality 

Notice of Decision: Approval – Effective Immediately 

Please be advised that on behalf of the Commissioner of the Department of Environmental Management, 

I have issued a decision regarding the enclosed matter. Pursuant to IC 13-17-3-4 and 326 IAC 2, this 

permit modification is effective immediately, unless a petition for stay of effectiveness is filed and granted, 

and may be revoked or modified in accordance with the provisions of IC 13-15-7-1. 

If you wish to challenge this decision, IC 4-21.5-3-7 and IC 13-15-7-3 require that you file a petition for 

administrative review. This petition may include a request for stay of effectiveness and must be submitted 

to the Office Environmental Adjudication, 100 North Senate Avenue, Government Center North, Room 

1049, Indianapolis, IN 46204, within eighteen (18) days of the mailing of this notice. The filing of a 

petition for administrative review is complete on the earliest of the following dates that apply to the filing: 

(1) the date the document is delivered to the Office of Environmental Adjudication (OEA); 

(2) the date of the postmark on the envelope containing the document, if the document is mailed to 

OEA by U.S. mail; or 

(3) The date on which the document is deposited with a private carrier, as shown by receipt issued 

by the carrier, if the document is sent to the OEA by private carrier. 

The petition must include facts demonstrating that you are either the applicant, a person aggrieved or 

adversely affected by the decision or otherwise entitled to review by law. Please identify the permit, 

decision, or other order for which you seek review by permit number, name of the applicant, location, date 

of this notice and all of the following: 

(1) the name and address of the person making the request; 

(2) the interest of the person making the request; 

(3) identification of any persons represented by the person making the request; 

(4) the reasons, with particularity, for the request; 

(5) the issues, with particularity, proposed for considerations at any hearing; and 

(6) identification of the terms and conditions which, in the judgment of the person making the 

request, would be appropriate in the case in question to satisfy the requirements of the law 

governing documents of the type issued by the Commissioner. 
Pursuant to 326 IAC 2-7-18(d), any person may petition the U.S. EPA to object to the issuance of a Title 

V operating permit or modification within sixty (60) days of the end of the forty-five (45) day EPA review 

period. Such an objection must be based only on issues that were raised with reasonable specificity 

during the public comment period, unless the petitioner demonstrates that it was impractible to raise such 

issues, or if the grounds for such objection arose after the comment period. 

To petition the U.S. EPA to object to the issuance of a Title V operating permit, contact: 

U.S. Environmental Protection Agency 

401 M Street 

Washington, D.C. 20406 

If you have technical questions regarding the enclosed documents, please contact the Office of Air 

Quality, Permits Branch at (317) 233-0178. Callers from within Indiana may call toll-free at 1-800-451-

6027, ext. 3-0178. 

 

Enclosures 

FNTV-PMOD.doc 1/10/05
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 We make Indiana a cleaner, healthier place to live. 

Mitchell E. Daniels, Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204-2251 

 (317) 232-8603

Thomas W. Easterly (800) 451-6027

Commissioner www.IN.gov/idem 

 

Ms. Debbie Tolliver July 7, 2006 

Lehigh Cement Company 

121 North First Street 

P.O. Box 97 

Mitchell, Indiana 47446 

 Re: 093-21975-00002 

 Significant Permit Modification to 

 Part 70 No.: T093- 5990-00002 

Dear Ms. Tolliver: 

Lehigh Cement Company, located at 121 North First Street, Mitchell, Indiana 47446 was issued a 

Part 70 permit on December 30, 2002 for a portland cement manufacturing plant. A letter requesting

changes to this permit was received on September 13, 2005. Lehigh requested its Part 70 Operating 

Permit be modified to allow the burning of coal and treated wood blends in Kiln #1 and Kiln #2. Lehigh’s 

application also included the request to utilize the Kiln #1 and Kiln #2 alternative fuel delivery systems 

(F19 and F20) to deliver the treated wood to Kilns #1 and Kiln #2. 

Pursuant to the provisions of 326 IAC 2-7-12 a significant permit modification to this permit is 

hereby approved. 

Part 70 Operating Permit No. 093-5990-00002 has been modified to: 

1. Include that Kiln #1 and Kiln #2 are each permitted to burn a blended fuel of coal and clean 

and/or treated wood where the blend has a maximum of 35% clean and/or treated wood by heat 

input in the facility descriptions in Section A.2(ccc) and (ddd), and in Section D.4; 

2. Amend IDEM’s address in Sections B.10(a), B.11(a), B.12(b)(5), B.15(b), B.17(a), B.18(b), 

B.20(a)(4), B.23(b), C.8(d), C.9(a), C.11, C.19(b), C.21(b), C.22(f), and on the Emergency 

Occurrence Report Form; 

3. Incorporate the credible evidence requirements of 326 IAC 1-1-6 into Condition B.25 and in the 

Table of Contents; 

4. Incorporate the 326 IAC 2-2-8(b) and (c) New Source Review record keeping and reporting 

requirements in Conditions C.20 and C.21 and in the Table of Contents; 

5. Correct the reference to the citation “40 CFR 63.1349(b)(2)” in Condition D.2.9(c); 

6. Clarify the NESHAP requirements in Condition D.2.11(a) consistent with 40 CFR § 63.1350; and 

7. Include in Condition D.4.1.1 that Kiln #1 and Kiln #2 are both permitted to burn a blended fuel of 

coal and treated wood where the blend has a maximum of up to 35% clean and/or treated wood 

by heat input. 

 

Other than the permit modifications detailed in this approval letter, all other 

conditions/requirements of Lehigh Cement Company’s Part 70 Operating Permit shall remain unchanged 

and unaffected. Please find enclosed a reprinted copy of the entire Part 70 Operating Permit. 

 Recycled Paper An Equal Opportunity Employer Please Recycle
Lehigh Cement Company Page 2 of 2 

Mitchell, Indiana Third SPM 093-21975-00002 

Permit Reviewer: Walter Habeeb 

 This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-21.5-3-5. 

If you have any questions on this matter, please contact Walter Habeeb OAQ, 100 North Senate Avenue, 

Indianapolis, Indiana, 46204-2251, or call at (800) 451-6027, and ask for Walter Habeeb or extension (2-

8422), or dial (317) 232-8422. 

 

 Sincerely, 

 Original signed by 

 Nisha Sizemore, Chief 

 Permit Branch 

 Office of Air Quality 

Attachments 

WH 

cc: File - Lawrence County 

 U.S. EPA, Region V 

 Lawrence County Health Department 
INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

 We make Indiana a cleaner, healthier place to live. 

Mitchell E. Daniels, Jr. 100 North Senate Avenue 

Governor Indianapolis, Indiana 46204-2251 

(317) 232-8603

Thomas W. Easterly (800) 451-6027

Commissioner www.in.gov/idem 

 

PA T

Lehigh Cement Company

to the conditions contained

rein, the source described in Section A (Source Summary) of this permit. 

 Air Act 

amended by the 1990 Clean Air Act Amendments), 40 CFR Part 70.6, IC 13-15 and IC 13-17. 

peration Permit No.: T093-5990-00002

RT 70 OPERATING PERMI

OFFICE OF AIR QUALITY

121 North First Street 

Mitchell, Indiana 47446

(herein known as the Permittee) is hereby authorized to operate subject

he

 

This permit is issued in accordance with 326 IAC 2 and 40 CFR Part 70 Appendix A and contains the 

conditions and provisions specified in 326 IAC 2-7 as required by 42 U.S.C. 7401, et. seq. (Clean

as

O

Original issued by: 

Janet G. McCabe, Assistant Commissioner

suance Date: December 30, 2002 

Office of Air Quality Expiration Date: December 30, 2007 

Is

First Significant Permit Modification No.: 093-16851-00002, issued on July 11, 2003 

Second Significant Permit Modification No.: 093-18649-00002, issued on November 5, 2004 

 

ion No.: 093-

21975-00002

First Administrative Amendment No.: 093-20912-00002, issued on April 8, 2005 

Second Administrative Amendment No.: 093-21136-00002, issued on April 26, 2005 

Minor Permit Modification No.: 

Significant Permit Modificat

 093-21919-00002, issued on April 17, 2006 

Conditions Affected: Table of Contents B.25, C.20, and

C.21; Kiln #1 and Kiln #2 Facility Descriptions in Section 

A.2(ccc), A.2 (ddd), and D.4; Amended IDEM’s address in

Sections B.10(a), B.11(a), B.12(b)(5), B.15(b), B.17(a),

B.18(b), B.20(a)(4), B.23(b), C.8(d), C.9(a), C.11, C.19(b),

C.21(b), C.22(f), and on the Emergency Occurrence Report

Form; Conditions B25, C.20, C.21, D.2.9(c), D.2.11(a), and

D.4.1.1.

Issued by: 

Chief 

Office of Air Quality 

suance Date: July 7, 2006

Expiration Date: December 30, 2007 

Nisha Sizemore,

Permits Branch

Is

Recycled Paper An Equal Opportunity Employer Please Recycle 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 2 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

TABLE OF CONTENTS

A SOURCE SUMMARY

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] 

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)]

A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] 

A.4 Part 70 Permit Applicability [326 IAC 2-7-2] 

B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-7-1]

B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] 

B.3 Enforceability [326 IAC 2-7-7] 

B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] 

B.5 Severability [326 IAC 2-7-5(5)] 

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] 

B.7 Duty to Supplement and Provide Information [326 IAC 2-7-4(b)] [326 IAC 2-7-5(6)(E)] 

B.8 Compliance with Permit Conditions [326 IAC 2-7-5(6)(A)] [326 IAC 2-7-5(6)(B)] 

B.9 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)] 

B.10 Annual Compliance Certification [326 IAC 2-7-6(5)] 

B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1), (3) and (13)][326 IAC 2-7-6(1) and (6)] 

B.12 Emergency Provisions [326 IAC 2-7-16]

B.13 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12]

B.14 Prior Permits Superseded [326 IAC 2-1.1-9.5] 

B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] 

B.16 Permit Modification, Reopening, Revocation and Reissuance, or Termination 

B.17 Permit Renewal [326 IAC 2-7-4] 

B.18 Permit Amendment or Modification [326 IAC 2-7-11][326 IAC 2-7-12] 

B.19 Permit Revision Under Economic Incentives and Other Programs

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] 

B.21 Source Modification Requirement [326 IAC 2-7-10.5]

B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] 

B.23 Transfer of Ownership or Operation [326 IAC 2-7-11] 

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] 

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-1-6] 

C SOURCE OPERATION CONDITIONS

Emission Limitations and Standards [326 IAC 2-7-5(1)]

C.1 Particulate Emission Limitations For Processes with Process Weight Rates less 

 than 100 pounds per hour [326 IAC 6-3-2] 

C.2 Opacity [326 IAC 5-1] 

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] 

C.4 Incineration [326 IAC 4-2] [326 IAC 9-1-2] 

C.5 Fugitive Dust Emissions [326 IAC 6-4] 

C.6 Operation of Equipment [326 IAC 2-7-6(6)] 

C.7 Stack Height [326 IAC 1-7]

C.8 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61.140]

Testing Requirements [326 IAC 2-7-6(1)]

C.9 Performance Testing [326 IAC 3-6] 

Compliance Requirements [326 IAC 2-1.1-11]

C.10 Compliance Requirements [326 IAC 2-1.1-11] 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 3 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)]

C.11 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

C.12 Maintenance of Continuous Opacity Monitoring Equipment [326 IAC 2-7-5(3)(A)(iii)] 

C.13 Monitoring Methods [326 IAC 3] 

C.14 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] 

 [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6]

C.15 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] 

C.16 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68 Subpart G]

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports 

 [326 IAC 2-7-5] 

C.18 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5] 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

C.19 Emission Statement [326 IAC 2-7-5(3)(C)(iii)] [326 IAC 2-7-5(7)] [326 IAC 2-7-19(c)] 

C.20 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [326 IAC 2-2] 

C.21 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11] [326 IAC 2-2] 

C.22 NESHAP Notification and Reporting Requirements [40 CFR 63, Subparts A and LLL] 

Stratospheric Ozone Protection

C.23 Compliance with 40 CFR 82 and 326 IAC 22-1 

D.1 FACILITY OPERATION CONDITIONS - Quarry Activities, Quarry Material Sizing, Cement

Kiln Dust Storage, Disposal, Mining, and Handling

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.1.1 Particulate [326 IAC 6-3-2]

D.1.2 Determination of Nonapplicability [40 CFR 60 Subparts A and F] [40 CFR 63 

 Subparts A and LLL] 

D.1.3 Prevention of Significant Deterioration [326 IAC 2-2] 

D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.1.5 Particulate Control 

 D.1.6 Testing requirement 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.1.7 Visible Emissions Notations 

D.1.8 Parametric Monitoring

D.1.9 Baghouse Inspections 

D.1.10 Broken or Failed Bag Detection 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.11 Record Keeping Requirements 

D.1.12 Reporting Requirements 

D.2 FACILITY OPERATION CONDITIONS - Raw Material Storage and Handling, Raw Mills

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.2.1 Particulate [326 IAC 6-3-2]

D.2.2 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

D.2.3 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

D.2.4 Sulfur Dioxide [326 IAC 7-1.1] 

D.2.5 NSPS for Portland Cement Plants [326 IAC 12] [40 CFR 60 Subpart F] 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 4 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.2.6 Determination of Nonapplicability [40 CFR 60 Subparts A and F] [40 CFR 63 Subparts 

 A and LLL]

D.2.7 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

D.2.8 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.2.9 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

D.2.10 Particulate Control 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.2.11 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

D.2.12 Visible Emissions Notations 

D.2.13 Parametric Monitoring

D.2.14 Baghouse Inspections 

D.2.15 Broken or Failed Bag Detection 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.16 Record Keeping Requirements 

D.2.17 Reporting Requirements 

D.3 FACILITY OPERATION CONDITIONS - Raw Mill Storage, Clinker Handling, Finish Mills,

Finish Material Storage, Bulk Loading and Packaging Facilities

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.3.1 Particulate [326 IAC 6-3-2]

D.3.2 Supersession of a Condition from a Previously Issued Construction Permit [326 IAC 12] 

 [40 CFR 60 Subpart F] 

D.3.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

D.3.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

D.3.5 Determination of nonapplicability [40 CFR 60 Subparts A and F] [40 CFR 63 Subparts 

 A and LLL]

D.3.6 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

D.3.7 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.3.8 Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

D.3.9 Particulate Control 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.3.10 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

D.3.11 Visible Emissions Notations 

D.3.12 Parametric Monitoring

D.3.13 Baghouse Inspections 

D.3.14 Broken or Failed Bag Detection 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.15 Record Keeping Requirements 

D.3.16 Reporting Requirements 

D.4 FACILITY OPERATION CONDITIONS - Kilns 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.4.1 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

D.4.1.1 Kiln #1 and Kiln #2 Partial Fuel Switch [326 IAC 2-2-2(d)(3)] 

D.4.2 Sulfur Dioxide (SO2) [326 IAC 7-1.1-1] 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 5 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.4.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

D.4.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

D.4.5 Compliance Assurance Monitoring (CAM) Plan [40 CFR 64] 

D.4.6 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements

D.4.7 NESHAP Testing Requirements [40 CFR 63, Subpart LLL] 

D.4.8 Testing Requirements 

D.4.9 Particulate Control 

D.4.10 Sulfur Dioxide Emissions from Coal Combustion and Coal Sulfur Content 

D.4.11 Continuous Emissions Monitoring [326 IAC 3-5][40 CFR 63, Subpart LLL] [326 IAC 

 2-1.1-11] 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.4.12 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL]

D.4.13 Preventive Inspections 

D.4.14 ESP Parametric Monitoring 

D.4.15 Opacity Readings 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.4.16 Record Keeping Requirements

D.4.17 Reporting Requirements

D.5 FACILITY OPERATION CONDITIONS - Clinker Coolers 

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.5.1 Prevention of Significant Deterioration (PSD) [326 IAC 2-2]

D.5.2 Determination of nonapplicability [40 CFR 60 Subparts A and F] 

D.5.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

D.5.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

D.5.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.5.6 NESHAP Testing Requirements [40 CFR 63, Subpart LLL] 

D.5.7 Cyclical Testing Requirements [326 IAC 2-7-6(1), (6)] [326 IAC 2-1.1-11] 

D.5.8 Continuous Emissions Monitoring [326 IAC 3-5] [40 CFR 63, Subpart LLL] [326 IAC 

 2-1.1-11] 

D.5.9 Particulate Control 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.5.10 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

D.5.11 Parametric Monitoring

D.5.12 Baghouse Inspections 

D.5.13 Broken or Failed Bag Detection 

D.5.14 Opacity Readings 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.5.15 Record Keeping Requirements

D.5.16 Reporting Requirements 

D.6 FACILITY CONDITIONS - Degreasers

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.6.1 Volatile Organic Compounds (VOC) [326 IAC 8-3-2] 

D.6.2 Volatile Organic Compounds (VOC) [326 IAC 8-3-5] 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 6 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.6.3 Determination of Nonapplicability [40 CFR 60.460 Subpart T] [40 CFR 60 Subparts A 

 and F] [40 CFR 63 Subparts A and LLL] 

D.7 FACILITY OPERATION CONDITIONS - Calcium sulfate material facilities/emission units 

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.7.1 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

D.7.2 NESHAP Emissions Limitation [326 IAC 20-27] [40 CFR 63.1348] 

D.7.3 Particulate [326 IAC 6-3-2]

D.7.4 PSD Minor Limit [326 IAC 2-2] 

D.7.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

Compliance Determination Requirements 

D.7.6 NESHAP Testing Requirements [326 IAC 20-27] [40 CFR 63.1349] 

D.7.7 Particulate Control 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.7.8 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)]

D.7.9 NESHAP Monitoring Requirements [326 IAC 20-27] [40 CFR 63.1350] 

D.7.10 Visible Emissions Notations 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.7.11 Record Keeping Requirements [326 IAC 20-27] [40 CFR 63.1355]

D.7.12 Reporting Requirements [326 IAC 20-27] [40 CFR 63.1354] 

D.7.13 Reporting Requirements 

Certification

Emergency Occurrence Report

Quarterly Reports

Quarterly Deviation and Compliance Monitoring Report 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 7 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION A SOURCE SUMMARY

This permit is based on information requested by the Indiana Department of Environmental Management

(IDEM), Office of Air Quality (OAQ). The information describing the source contained in conditions A.1 

through A.3 and the facility/emissions unit description boxes in Sections D of the permit, is descriptive

information and does not constitute enforceable conditions. However, the Permittee should be aware that

a physical change or a change in the method of operation that may render this descriptive information

obsolete or inaccurate may trigger requirements for the Permittee to obtain additional permits or seek

modification of this permit pursuant to 326 IAC 2, or change other applicable requirements presented in

the permit application. 

A.1 General Information [326 IAC 2-7-4(c)] [326 IAC 2-7-5(15)] [326 IAC 2-7-1(22)] 

The Permittee owns and operates a portland cement manufacturing plant. 

Responsible Official: Plant Manager 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: 121 North First Street, P.O. Box 97, Mitchell, Indiana 47446 

Phone Number: (812) 849-2191 

SIC Code: 3241 

County Location: Lawrence 

Source Location Status: Attainment or unclassified for all criteria pollutants 

Source Status: Part 70 Permit Program 

Major Source under PSD Rules 

Major Source, Section 112 of the Clean Air Act 

One of the 28 listed source categories

A.2 Emission Units and Pollution Control Equipment Summary [326 IAC 2-7-4(c)(3)][326 IAC 2-7-

5(15)] 

This stationary source consists of the following emission units and pollution control devices: 

The quarry activities, as follows: 

(a) Drilling/blasting, hauling, handling and storage, identified as F01, commenced prior to

1971, with associated fugitive particulate matter (PM) emissions. 

The quarry material sizing facilities/emissions units, as follows: 

(b) One (1) primary crusher, identified as EU01, constructed in 1965, with a nominal rate of 

975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

QDC2, and exhausting to one (1) stack, identified as S-QDC2. 

(c) One (1) surge bin and transfer system, identified as EU02, constructed in 1965, with a

nominal rate of 975 tons per hour, with PM emissions controlled by one (1) baghouse, 

identified as QDC3, and exhausting to one (1) stack, identified as S-QDC3. 

(d) One (1) secondary crusher, identified as EU03, constructed in 1965, with a nominal rate

of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

QDC4, and exhausting to one (1) stack, identified as S-QDC4. 

(e) One (1) tertiary crusher, identified as EU04, constructed in 1965, with a nominal rate of

975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

QDC4, and exhausting to one (1) stack, identified as S-QDC4. 

(f) One (1) north screen house, identified as EU05, constructed in 1965, with a nominal rate 

of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 8 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

QDC5, and exhausting to one (1) stack, identified as S-QDC5. 

(g) One (1) south screen house, identified as EU06, constructed in 1965, with a nominal rate

of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

QDC6, and exhausting to one (1) stack, identified as S-QDC6. 

(h) One (1) belt #7 to belt #8 conveyor transfer point, identified as EU07, constructed in 

1965, with a nominal rate of 975 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as QDC7, and exhausting to one (1) stack, identified as S-QDC7. 

(i) One (1) belt #8 to belt #9 conveyor transfer point, identified as EU08, constructed in 

1965, with a nominal rate of 975 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as QDC8, and exhausting to one (1) stack, identified as S-QDC8. 

(j) One (1) belt #9 to belt #10 conveyor transfer point, identified as F02, constructed in 1965,

with a nominal rate of 975 tons per hour, using seasonal water suppression to control PM 

emissions, and exhausting directly to the atmosphere. 

The cement kiln dust storage, disposal, mining, and handling facilities/emissions units, as follows: 

(k) One (1) cement kiln dust (CKD) bin, identified as EU24, constructed in 1959, with a

nominal rate of 100 tons per hour, with PM emissions controlled by one (1) baghouse, 

identified as KDC7, and exhausting to one (1) stack, identified as S-KDC7. 

(l) One (1) CKD truck unloading system, identified as EU24A, constructed in 1959, with a

nominal rate of 60 tons per hour, with PM emissions controlled by one (1) baghouse,

identified as KDC7A, and exhausting to one (1) stack, identified as S-KDC7A. 

(m) One (1) CKD mixer, identified as EU24B, constructed in 1999, with a nominal rate of 104

tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC7B, 

and exhausting to one (1) stack, identified as S-KDC7B. 

(n) One (1) CKD truck loadout, identified as F07, constructed in 1999, with a nominal rate of 

104 tons per hour, with PM emissions uncontrolled, and exhausting directly to the

atmosphere. 

(o) CKD disposal and mining facilities, identified as F05, constructed in 1999, with particulate

matter emissions uncontrolled, and exhausting directly to the atmosphere. 

The raw material handling and storage facilities/emissions units, as follows: 

(p) A conveying system to transport raw material to storage, identified as EU09, constructed

in 1960, with a nominal rate of 200 tons per hour, with PM emissions controlled by one

(1) baghouse, identified as RMDC1, and exhausting to one (1) stack, identified as SRMDC1. 

(q) One (1) shale crusher, identified as EU10, constructed in 1961, with a nominal rate of

200 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

RMDC2, and exhausting to one (1) stack, identified as S-RMDC2. 

(r) One (1) material storage building, identified as F03, constructed in 1959-1960, with

fugitive emissions from various conveyors and storage piles controlled by partial 

enclosure and exhausting directly to the atmosphere. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 9 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(s) One (1) coal unloading building, identified as F08, constructed in 1960, with particulate 

matter emissions controlled by partial enclosure and exhausting directly to the 

atmosphere. 

(t) One (1) coal pile, identified as F04, storage commencing prior to 1971, with particulate

matter emissions uncontrolled, and exhausting directly to the atmosphere. 

(u) Raw material stockpiles collectively, identified as F09, storage commencing prior to 1971, 

used for temporary storage of various feed materials, including gypsum, foundry sand, 

mill scale, and slag, with particulate matter emissions uncontrolled, and exhausting to the 

atmosphere. 

Kiln #1 and Kiln #2 Alternative Fuel Delivery Systems as follows:

(u.1) One (1) Kiln #1 alternative fuel delivery system, identified as F19, consisting of a

partially enclosed hopper exhausting to the atmosphere and a series of totally 

enclosed conveyors, with a nominal throughput of 87,600 tons per year. 

 

(u.2) One (1) Kiln #2 alternative fuel delivery system, identified as F20, consisting of a

partially enclosed hopper exhausting to the atmosphere and a series of totally 

enclosed conveyors, with a nominal throughput of 87,600 tons per year. 

The raw mill facilities/emissions units, as follows: 

(v) One (1) raw mill #1, identified as EU11, constructed in 1961, with a nominal rate of 100 

tons per hour and including a natural gas-fired burner, identified as EU11A, with a

maximum heat input rate of 20 million British thermal units (MMBtu) per hour, with PM

emissions controlled by one (1) baghouse, identified as RMDC3, and exhausting to one

(1) stack, identified as S-RMDC3. 

(w) One (1) raw mill #2, identified as EU12, constructed in 1961, with a nominal rate of 100 

tons per hour and including a natural gas-fired burner, identified as EU12A, with a

maximum heat input rate of 20 million British thermal units (MMBtu) per hour, with PM

emissions controlled by one (1) baghouse, identified as RMDC4, and exhausting to one

(1) stack, identified as S-RMDC4. 

The raw mill storage facilities/emissions units, as follows: 

(x) Blending bins, identified as EU13, constructed in 1961, with a combined nominal rate of 

250 tons per hour, with PM emissions controlled by two (2) baghouses, identified as 

RMDC5 and RMDC6, and each exhausting to separate stacks, identified as S-RMDC5 

and S-RMDC6, respectively. 

(y) Kiln supply silos, identified as EU14, constructed in 1961, with a combined nominal rate 

of 250 tons per hour, with PM emissions controlled by two (2) baghouses, identified as

RMDC7 and RMDC8, and each exhausting to separate stacks, identified as S-RMDC7 

and S-RMDC8, respectively. 

(z) One (1) kiln feed bin #1, identified as EU18, constructed in 1959, with a nominal rate of 

66 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC1, 

and exhausting to one (1) stack, identified as S-KDC1. 

(aa) One (1) kiln feed bin #2, identified as EU20, constructed in 1959, with a nominal rate of 

66 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC3, 

and exhausting to one (1) stack, identified as S-KDC3. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 10 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(bb) One (1) kiln feed bin #3, identified as EU22, constructed in 1974, with a nominal rate of 

73 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC5, 

and exhausting to one (1) stack, identified as S-KDC5. 

The clinker handling facilities/emissions units, as follows:

(cc) One (1) south storage drag, identified as EU25, constructed in 1974, with a nominal rate

of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

FDC1, and exhausting to one (1) stack, identified as S-FDC1. 

(dd) One (1) north clinker tower, identified as EU26a, constructed in 1959, with a nominal rate

of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

FDC2, and exhausting to one (1) stack, identified as S-FDC2. 

(ee) One (1) North storage drag, identified as EU26b, constructed in 1959, with a nominal rate

of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

FDC2, and exhausting to one (1) stack, identified as S-FDC2. 

(ff) One (1) scrap bin clinker ladder, identified as EU26c, constructed in 1993, with a nominal

rate of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as FDC2, and exhausting to one (1) stack, identified as S-FDC2. 

(gg) One (1) south clinker tower, identified as EU27, constructed in 1974, with a nominal rate

of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

FDC3, and exhausting to one (1) stack, identified as S-FDC3. 

(hh) One (1) hot spout clinker ladder, identified as EU28, constructed in 1993, with a nominal

rate of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as FDC4, and exhausting to one (1) stack, identified as S-FDC4. 

(ii) One (1) pan clinker conveyor, identified as EU29, constructed in 1979, with a nominal 

rate of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as FDC5, and exhausting to one (1) stack, identified as S-FDC5. 

(jj) One (1) east clinker ladder, identified as EU30, constructed in 1993, with a nominal rate

of 120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

FDC6, and exhausting to one (1) stack, identified as S-FDC6. 

(kk) One (1) roll crusher, identified as EU31, constructed in 1987, with a nominal rate of 240 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC7,

and exhausting to one (1) stack, identified as S-FDC7. 

Note: The scrap bin clinker ladder (EU26c), the hot spout clinker ladder (EU28), and the east

clinker ladder (EU30) are not emission units; they are flaps which are used to reduce the

drop heights from the north clinker tower, the south clinker tower, and the north storage 

drag, respectively, which reduce particulate emissions. 

The finish mill facilities/emissions units, as follows: 

(ll) One (1) finish mill #1 with associated feed bin, identified as EU32, constructed in 1959, 

with a nominal rate of 37 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as FDC8, and exhausting to one (1) stack, identified as S-FDC8. 

(mm) One (1) finish mill #2 with associated feed bin, identified as EU33, constructed in 1959, 

with a nominal rate of 37 tons per hour, with PM emissions controlled by one (1) 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 11 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

baghouse, identified as FDC9, and exhausting to one (1) stack, identified as S-FDC9. 

(nn) One (1) finish mill #3 with associated feed bin, identified as EU34, constructed in 1959, 

with a nominal rate of 37 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as FDC10, and exhausting to one (1) stack, identified as S-FDC10. 

(oo) One (1) finish mill #4 with associated feed bin, identified as EU35, constructed in 1974, 

with a nominal rate of 50 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as FDC11, and exhausting to one (1) stack, identified as S-FDC11. 

(pp) One (1) finish mill #4 separator, identified as EU36, constructed in 1989, with a nominal

rate of 50 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

FDC12, and exhausting to one (1) stack, identified as S-FDC12. 

(qq) One (1) lime bin, identified as EU38, constructed in 1993, with a nominal rate of 6 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as FDC14, and

exhausting to one (1) stack, identified as S-FDC14. 

The finish material storage facilities/emissions units, as follows: 

(rr) One (1) surge bin, identified as EU37, constructed in 1959, with a nominal rate of 35 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as FDC13, and

exhausting to one (1) stack, identified as S-FDC13. 

(ss) A north and south silo operation consisting of thirty (30) storage silos, identified as 

EU39A and EU39B, constructed in 1959, with a nominal rate of 60 tons per hour, with PM

emissions controlled by two (2) baghouses, identified as SDC1 and SDC2, and

exhausting to two (2) stacks, identified as S-SDC1 and S-SDC2, respectively. 

(tt) A silo transfer system, identified as EU40A and EU40B, constructed in 1959, with a

nominal rate of 300 tons per hour, with PM emissions controlled by two (2) baghouses, 

identified as SDC3 and SDC4, and exhausting to two (2) stacks, identified as S-SDC3

and S-SDC4, respectively. 

The bulk loading and packaging facilities/emissions units, as follows: 

(uu) One (1) east truck loadout bin, identified as EU41, constructed in 1959, with a nominal 

rate of 450 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as SDC5, and exhausting to one (1) stack, identified as S-SDC5. 

(vv) One (1) east truck vaculoader, identified as EU42, constructed in 1959, with a nominal

rate of 450 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as SDC6, and exhausting to one (1) stack, identified as S-SDC6. 

(ww) One (1) west truck loadout bin, identified as EU43, constructed in 1959, with a nominal 

rate of 450 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as SDC7, and exhausting to one (1) stack, identified as S-SDC7. 

(xx) One (1) west truck vaculoader, identified as EU44, constructed in 1959, with a nominal 

rate of 450 tons per hour, with PM emissions controlled by one (1) baghouse, identified

as SDC8, and exhausting to one (1) stack, identified as S-SDC8. 

(yy) One (1) truck loadout station, identified as F06, constructed in 1959, with a nominal rate

of 30 tons per hour, and exhausting directly to the atmosphere. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 12 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(zz) One (1) railroad loadout bin, identified as EU45, constructed in 1959, with a nominal rate

of 240 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

SDC9, and exhausting to one (1) stack, identified as S-SDC9. 

(aaa) One (1) articuloader, identified as EU46, constructed in 1959, with a nominal rate of 240

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC10,

and exhausting to one (1) stack, identified as S-SDC10. 

(bbb) One (1) packing machine, identified as EU47, constructed in 1984, with a nominal rate of 

40 tons per hour, with PM emissions controlled by two (2) baghouses, identified as

SDC11 and SDC12, and exhausting to two (2) stacks, identified as S-SDC11 and SSDC12, respectively. 

The kiln facilities/emissions units, as follows: 

(ccc) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and modified to 

a one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, 

with a nominal production rate of 38 tons per hour, with PM emissions controlled by one

(1) electrostatic precipitator (ESP), identified as KP1, and dioxins/ furans controlled and 

SO2 partially controlled by a Water Spray Tower, and exhausting to one (1) stack, 

identified as S-KP1. Kiln #1 is also permitted to use a blended fuel of coal and pressed 

paper making waste where the blend has a maximum of 20% pressed paper making

waste by heat input. 

Kiln #1 is permitted to use a blended fuel of coal and clean and/or treated wood where 

the blend has a maximum of up to 35% clean and/or treated wood by heat input. 

(ddd) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and modified to 

a one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, 

with a nominal production rate of 38 tons per hour, with PM emissions controlled by one

(1) electrostatic precipitator (ESP), identified as KP2, and dioxins/ furans controlled and 

SO2 partially controlled by a Water Spray Tower, and exhausting to one (1) stack, 

identified as S-KP1. Kiln #2 is also permitted to use a blended fuel of coal and pressed 

paper making waste where the blend has a maximum of 20% pressed paper making

waste by heat input. 

Kiln #2 is permitted to use a blended fuel of coal and clean and/or treated wood where the 

blend has a maximum of up to 35% clean and/or treated wood by heat input.

(eee) One (1) kiln #3, identified as EU17, constructed in 1974 as a one-stage preheater kiln, 

with a heat input rate of 118 million Btu per hour, with a nominal production rate of 43

tons per hour, with PM emissions controlled by one (1) electrostatic precipitator (ESP), 

identified as KP3, and exhausting to one (1) stack, identified as S-KP2. Kiln #3 is also 

permitted to use a blended fuel of coal and pressed paper making waste where the blend 

has a maximum of 20% pressed paper making waste by heat input. 

The clinker cooler facilities/emissions units, as follows: 

(fff) One (1) clinker cooler #1, identified as EU19, constructed in 1959, with a nominal rate of

38 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC2, 

and exhausting to one (1) stack, identified as S-KDC2. 

(ggg) One (1) clinker cooler #2, identified as EU21, constructed in 1959, with a nominal rate of

38 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC4, 

and exhausting to one (1) stack, identified as S-KDC4. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 13 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(hhh) One (1) clinker cooler #3, identified as EU23, constructed in 1974, with a nominal rate of

43 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC6, 

and exhausting to one (1) stack, identified as S-KDC6. 

Calcium sulfate material facilities/emission units, consisting of the following: 

(iii) Two (2) storage piles, identified as F10 and F12, with emissions uncontrolled and

exhausting to the atmosphere, potential capacity: 0.10 and 0.05 acres, respectively. 

(jjj) One (1) synthetic gypsum hopper, identified as F11, with emissions uncontrolled and 

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(kkk) One (1) synthetic gypsum weight belt, identified as F15, with emissions uncontrolled and

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(lll) One (1) raw material hopper, identified as F13, with emissions uncontrolled and

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(mmm) One (1) raw material weight belt, identified as F16, with emissions uncontrolled and 

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(nnn) One (1) main belt #1, identified as F17, with emissions uncontrolled and exhausting to 

the atmosphere, maximum throughput: 100 tons per hour. 

(ooo) One (1) enclosed CKD conveyor #1, identified as EU50, maximum throughput: 50 tons

per hour. 

(ppp) One (1) CKD storage silo, identified as EU48, previously used as a blending bin, with 

particulate emissions controlled by an existing baghouse, identified as RMDC5, and

exhausting to stack S-RMDC5, maximum throughput: 50 tons per hour. 

(qqq) One (1) enclosed CKD conveyor #2, identified as EU51, maximum throughput: 50 tons

per hour. 

(rrr) One (1) enclosed pugmill, identified as EU49, maximum capacity: 100 tons per hour. 

(sss) One (1) main belt #2, identified as F18, with emissions uncontrolled and exhausting to 

the atmosphere, maximum throughput: 100 tons per hour. 

(ttt) One (1) outdoor, partially enclosed calcium sulfate material storage pile, identified as 

F14, potential capacity: 0.10 acre. 

A.3 Specifically Regulated Insignificant Activities [326 IAC 2-7-1(21)] [326 IAC 2-7-4(c)] 

[326 IAC 2-7-5(15)] 

(1) This stationary source includes the following specifically regulated insignificant activities: 

Degreasing operations that do not exceed 145 gallons per 12 months, except if subject to 

326 IAC 20-6. [326 IAC 8-3-2] [326 IAC 8-3-5] 

(2) This stationary source also includes the following insignificant activities, as defined in 326

IAC 2-7-1(21): 

(a) Space heaters, process heaters, or boilers using the following fuels: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 14 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(1) Natural gas-fired combustion sources with heat input equal to or less 

than ten million (10,000,000) Btu per hour. 

(2) Fuel oil-fired combustion sources with heat input equal to or less than 

two million (2,000,000) Btu per hour and firing fuel containing less than

five-tenths (0.5) percent sulfur by weight.

(b) A gasoline fuel transfer and dispensing operation handling less than or equal to

1,300 gallons per day, such as filling of tanks, locomotives, automobiles, having 

a storage capacity less than or equal to 10,500 gallons. 

(c) The following VOC and HAP storage containers: 

(1) Storage tanks with capacity less than or equal to 1,000 gallons and

annual throughput less than 12,000 gallons. 

(2) Vessels storing lubricating oils, hydraulic oils, machining oils, and

machining fluids. 

(d) Refractory storage not requiring air pollution control equipment. 

(e) Application of oils, greases, lubricants, or other nonvolatile materials applied as

temporary protective coatings. 

(f) Replacement or repair of electrostatic precipitators, bags in baghouses and filters 

in other air filtration equipment. 

(g) Heat exchanger cleaning and repair. 

(h) Paved and unpaved roads and parking lots with public access. 

(i) Underground conveyors with PM controlled by total enclosure. 

(j) On-site fire and emergency response training approved by the department. 

(k) Emergency generators as follows: 

(1) Gasoline generators not exceeding 110 horsepower. 

(2) Diesel generators not exceeding 1600 horsepower. 

(l) Stationary fire pumps. 

(m) A laboratory as defined in 326 IAC 2-7-1 (21)(D). 

(n) Other categories with emissions below insignificant thresholds as follows: 

(1) Two (2) grinding aid storage tanks. 

(2) Three (3) Airalon/Airplas storage tanks. 

(3) Three (3) coal mills, with nominal rates of 5, 6, and 6 tons per hour, with 

particulate matter controlled by total enclosure. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 15 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(4) One coal feeder conveyor and one coal unloading conveyor, with

nominal rates of 250 tons per hour and 260 tons per hour, respectively, 

constructed prior to August 17, 1971, with particulate matter emissions 

controlled by total enclosure. 

A.4 Part 70 Permit Applicability [326 IAC 2-7-2] 

This stationary source is required to have a Part 70 permit by 326 IAC 2-7-2 (Applicability) 

because: 

(a) It is a major source, as defined in 326 IAC 2-7-1(22); and 

(b) It is a source in a source category designated by the United States Environmental

Protection Agency (U.S. EPA) under 40 CFR 70.3 (Part 70 - Applicability). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 16 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION B GENERAL CONDITIONS

B.1 Definitions [326 IAC 2-7-1]

Terms in this permit shall have the definition assigned to such terms in the referenced regulation. 

In the absence of definitions in the referenced regulation, the applicable definitions found in the

statutes or regulations (IC 13-11, 326 IAC 1-2 and 326 IAC 2-7) shall prevail. 

B.2 Permit Term [326 IAC 2-7-5(2)] [326 IAC 2-1.1-9.5] 

This permit is issued for a fixed term of five (5) years from the issuance date of this permit, as 

determined in accordance with IC 4-21.5-3-5(f) and IC 13-15-5-3. Subsequent revisions,

modifications, or amendments to this permit do not affect the expiration date. 

B.3 Enforceability [326 IAC 2-7-7] 

Unless otherwise stated, all terms and conditions in this permit except the facility/emissions unit 

descriptions contained in Sections A.1 through A.3 and Sections D, including any provisions 

designed to limit the source's potential to emit, are enforceable by IDEM, the United States 

Environmental Protection Agency (U.S. EPA) and citizens in accordance with the Clean Air Act. 

B.4 Termination of Right to Operate [326 IAC 2-7-10] [326 IAC 2-7-4(a)] 

The Permittee's right to operate this source terminates with the expiration of this permit unless a

timely and complete renewal application is submitted at least nine (9) months prior to the date of 

expiration of the source’s existing permit, consistent with 326 IAC 2-7-3 and 326 IAC 2-7-4(a). 

B.5 Severability [326 IAC 2-7-5(5)] 

The provisions of this permit are severable; a determination that any portion of this permit is 

invalid shall not affect the validity of the remainder of the permit. 

B.6 Property Rights or Exclusive Privilege [326 IAC 2-7-5(6)(D)] 

This permit does not convey any property rights of any sort, or any exclusive privilege. 

B.7 Duty to Supplement and Provide Information [326 IAC 2-7-4(b)] [326 IAC 2-7-5(6)(E)] [326 IAC 2-7-6(6)] 

(a) The Permittee shall furnish to IDEM, OAQ, within a reasonable time, any information that

IDEM, OAQ, may request in writing to determine whether cause exists for modifying, 

revoking and reissuing, or terminating this permit, or to determine compliance with this

permit. The submittal by the Permittee does require the certification by the “responsible

official” as defined by 326 IAC 2-7-1(34). Upon request, the Permittee shall also furnish

to IDEM, OAQ copies of records required to be kept by this permit or, for information

claimed to be confidential, the Permittee may furnish such records directly to the U.S. 

EPA along with a claim of confidentiality. [326 IAC 2-7-5(6)(E)] 

(b) The Permittee may include a claim of confidentiality in accordance with 326 IAC 17.1.

When furnishing copies of requested records directly to U. S. EPA, the Permittee may

assert a claim of confidentiality in accordance with 40 CFR 2, Subpart B. 

B.8 Compliance with Permit Conditions [326 IAC 2-7-5(6)(A)] [326 IAC 2-7-5(6)(B)] 

(a) The Permittee must comply with all conditions of this permit. Noncompliance with any 

provisions of this permit is grounds for: 

(1) Enforcement action; 

(2) Permit termination, revocation and reissuance, or modification; or 

(3) Denial of a permit renewal application. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 17 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(b) Noncompliance with any provisions of this permit, except any provision specifically 

designated as not federally enforceable, constitutes a violation of the Clean Air Act. 

(c) It shall not be a defense for the Permittee in an enforcement action that it would have

been necessary to halt or reduce the permitted activity in order to maintain compliance

with the conditions of this permit. 

(d) An emergency does constitute an affirmative defense in an enforcement action provided

the Permittee complies with the applicable requirements set forth in Section B - 

Emergency Provisions. 

B.9 Certification [326 IAC 2-7-4(f)] [326 IAC 2-7-6(1)] [326 IAC 2-7-5(3)(C)] 

(a) Where specifically designated by this permit or required by an applicable requirement, 

any application forms, report, or compliance certification submitted shall contain certification by a responsible official of truth, accuracy, and completeness. This certification shall

state that, based on information and belief formed after reasonable inquiry, the

statements and information in the document are true, accurate, and complete. 

(b) One (1) certification shall be included, using the attached Certification Form, with each 

submittal requiring certification. 

(c) A responsible official is defined at 326 IAC 2-7-1(34). 

B.10 Annual Compliance Certification [326 IAC 2-7-6(5)] 

(a) The Permittee shall annually submit a compliance certification report which addresses 

the status of the source’s compliance with the applicable terms and conditions contained

in this permit, including emission limitations, standards, or work practices. The initial 

certification shall cover the time period from the date of final permit issuance through 

December 31 of the same year and shall be submitted in letter form no later than July 1 

of the following year to the addresses listed below. Subsequent certifications shall cover 

the time period from January 1 to December 31 of the previous year, and shall be

submitted in letter form no later than July 1 of each year to: 

Indiana Department of Environmental Management 

Compliance Data Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

and 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

(b) The annual compliance certification report required by this permit shall be considered

timely if the date postmarked on the envelope or certified mail receipt, or affixed by the

shipper on the private shipping receipt, is on or before the date it is due. If the document 

is submitted by any other means, it shall be considered timely if received by IDEM, OAQ, 

on or before the date it is due. 

(c) The annual compliance certification report shall include the following: 

(1) The appropriate identification of each term or condition of this permit that is the

basis of the certification; 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 18 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(2) The compliance status; 

(3) Whether compliance was continuous or intermittent; 

(4) The methods used for determining the compliance status of the source, currently 

and over the reporting period consistent with 326 IAC 2-7-5(3); 

(5) Such other facts, as specified in Section D of this permit, as IDEM, OAQ, may 

require to determine the compliance status of the source. 

The submittal by the Permittee does require the certification by the “responsible official” 

as defined by 326 IAC 2-7-1(34). 

B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1), (3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 1-6-3] 

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare

and maintain Preventive Maintenance Plans (PMP) within ninety (90) days after issuance

of this permit, including the following information on each facility/emissions unit: 

(1) Identification of the individual(s) responsible for inspecting, maintaining, and

repairing emission control devices; 

(2) A description of the items or conditions that will be inspected and the inspection

schedule for said items or conditions; 

(3) Identification and quantification of the replacement parts that will be maintained

in inventory for quick replacement. 

If due to circumstances beyond the Permittee’s control, the PMP cannot be prepared and 

maintained within the above time frame, the Permittee may extend the date an additional 

ninety (90) days provided the Permittee notifies: 

Indiana Department of Environmental Management 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

The PMP and the PMP extension notification do not require the certification by the 

“responsible official” as defined by 326 IAC 2-7-1(34). 

(b) The Permittee shall implement the PMPs, including any required record keeping, as 

necessary to ensure that failure to implement a PMP does not cause or contribute to an

exceedance of any limitation on emissions or potential to emit. 

(c) A copy of the PMPs shall be submitted to IDEM, OAQ, upon request and within a 

reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, 

OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance 

causes or is the primary contributor to an exceedance of any limitation on emissions or

potential to emit. The PMP does not require the certification by the “responsible official” 

as defined by 326 IAC 2-7-1(34). 

(d) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation,

Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the 

PMP requirements of 326 IAC 1-6-3 for that unit. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 19 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

B.12 Emergency Provisions [326 IAC 2-7-16]

(a) An emergency, as defined in 326 IAC 2-7-1(12), is not an affirmative defense for an

action brought for noncompliance with a federal or state health-based emission limitation. 

(b) An emergency, as defined in 326 IAC 2-7-1(12), constitutes an affirmative defense to an

action brought for noncompliance with a technology-based emission limitation if the 

affirmative defense of an emergency is demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that describe the following: 

(1) An emergency occurred and the Permittee can, to the extent possible, identify 

the causes of the emergency; 

(2) The permitted facility/emissions unit was at the time being properly operated; 

(3) During the period of an emergency, the Permittee took all reasonable steps to

minimize levels of emissions that exceeded the emission standards or other 

requirements in this permit; 

(4) For each emergency lasting one (1) hour or more, the Permittee notified IDEM, 

OAQ, within four (4) daytime business hours after the beginning of the emergency, or after the emergency was discovered or reasonably should have been

discovered; 

Telephone Number: 1-800-451-6027 (ask for Office of Air Quality, Compliance

Section), or 

Telephone Number: 317-233-5674 (ask for Compliance Section) 

Facsimile Number: 317-233-5967 

(5) For each emergency lasting one (1) hour or more, the Permittee submitted the

attached Emergency Occurrence Report Form, either by mail or facsimile to: 

Indiana Department of Environmental Management 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

within two (2) working days of the time when emission limitations were exceeded

due to the emergency. 

The notice fulfills the requirement of 326 IAC 2-7-5(3)(C)(ii) and must contain the 

following: 

(A) A description of the emergency; 

(B) Any steps taken to mitigate the emissions; and 

(C) Corrective actions taken. 

The notification which shall be submitted by the Permittee does not require the

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(6) The Permittee immediately took all reasonable steps to correct the emergency. 

(c) In any enforcement proceeding, the Permittee seeking to establish the occurrence of an

emergency has the burden of proof. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 20 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) This emergency provision supersedes the malfunction rule, 326 IAC 1-6 (except the

requirement for a PMP in 326 IAC 1-6-3), for sources subject to 326 IAC 2-7 after the

effective date of 326 IAC 2-7. This permit condition is in addition to any emergency or 

upset provision contained in any applicable requirement. 

(e) IDEM, OAQ, may require that the Preventive Maintenance Plans required under 326 IAC 

2-7-4(c)(9) be revised in response to an emergency. 

(f) Failure to notify IDEM, OAQ, by telephone, facsimile, or other agreed upon method, of an

emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this 

condition shall constitute a violation of 326 IAC 2-7 and any other applicable rules. 

(g) If the emergency situation causes a deviation from a technology-based limit, the 

Permittee may continue to operate the affected emitting facilities/emissions units during

the emergency provided the Permittee immediately takes all reasonable steps to correct

the emergency and minimize emissions. 

B.13 Permit Shield [326 IAC 2-7-15] [326 IAC 2-7-20] [326 IAC 2-7-12]

(a) Pursuant to 326 IAC 2-7-15, the Permittee has been granted a permit shield. The permit 

shield provides that compliance with the conditions of this permit shall be deemed in

compliance with any applicable requirements as of the date of permit issuance, provided

that either the applicable requirements are included and specifically identified in this 

permit or the permit contains an explicit determination or concise summary of a determination that other specifically identified requirements are not applicable. The term

"applicable requirements" shall have the meaning set forth in 326 IAC 2-7-1(6). The 

issuance or possession of this permit shall not alone constitute a defense against an 

alleged violation of any law, regulation or standard, except for the requirement to obtain a 

Part 70 permit under 326 IAC 2-7 or for applicable requirements for which a permit shield

has been granted. 

This permit shield does not extend to applicable requirements which are promulgated

after the date of issuance of this permit unless this permit has been modified to reflect

such new requirements. 

(b) From the effective date of this permit, the Permittee’s right to operate this source is

pursuant to this Title V permit. All previously issued operating permits, including those

listed below, are superseded by this permit. All operating permits that are currently in 

effect are hereby revoked by the issuance of this Title V Permit and are no longer in 

effect. 

(1) OP 47-01-88-0072, issued on May 30, 1984; 

(2) OP 47-01-88-0073, issued on May 30, 1984; 

(3) OP 47-01-88-0074, issued on May 30, 1984; 

(4) OP 47-01-88-0075, issued on May 30, 1984; 

(5) OP 47-01-88-0076, issued on May 30, 1984; 

(6) OP 47-01-88-0077, issued on May 30, 1984; 

(7) OP 47-01-88-0078, issued on May 30, 1984; 

(8) OP 47-01-88-0079, issued on May 30, 1984; 

(9) OP 47-01-88-0080, issued on May 30, 1984; 

(10) OP 47-01-92-0097, issued on July 22, 1987; and 

(11) OP 47-04-92-0099, issued on March 30, 1988. 

(c) Construction Permit CP093-4598-00002, issued on February 27, 1998, which allowed the 

source to burn waste tires as a fuel in their kilns, has been revoked. Subsequent 

amendments and modifications to that permit including A093-9623 issued April 29, 1998, 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 21 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

093-11248 issued September 9, 1999, and 093-11552 issued October 23, 2000 have

also been revoked. The source is no longer permitted to burn waste tires. 

(d) In addition to the nonapplicability determinations set forth in Sections D of this permit, the 

IDEM, OAQ has made the following nonapplicability determinations regarding this

source:

(1) None of the petroleum storage tanks listed in Section A.3 of this permit are

subject to the requirements of the New Source Performance Standard (NSPS) 

326 IAC 12 and 40 CFR 60.110 (Subpart K), or 40 CFR 60.110a (Subpart Ka) 

because all the petroleum storage tanks have capacities less than 40,000 

gallons. 

(2) None of the storage tanks listed in Section A.3 of this permit are subject to the 

NSPS 326 IAC 12, 40 CFR 60.110b (Subpart Kb) because the tanks have

capacities less than 10,500 gallons, or do not contain a substance categorized as 

volatile organic liquid (VOL). 

(3) The quarry activities, the quarry material sizing facilities/emission units, and the

raw material handling and storage facilities/emission units listed in this permit are

not subject to the requirements of the NSPS 326 IAC 12, 40 CFR 60.670

(Subpart OOO) because they were constructed prior to the applicability date of 

August 31, 1983. 

(4) None of the other facilities/emission units listed in this permit are subject to the 

requirements of the NSPS 326 IAC 12, 40 CFR 60.670 (Subpart OOO) because 

they are not affected facilities and/or this rule specifically exempts facilities that 

are subject to the requirements of the NSPS, 40 CFR 60.60 (Subpart F), and 

facilities which follow in the plant process any facility which is subject to the 

requirements of the NSPS, 40 CFR 60.60 (Subpart F). 

(5) None of the facilities/emission units listed in this permit are subject to the

requirements of the NSPS 326 IAC 12, 40 CFR 60.730 (Subpart UUU) because

the source does not fit the definition of a mineral processing plant. 

(6) Paragraphs #2 through #7 of exemption CP 093-9431-00002, issued August 19, 

1999, list requirements pursuant to Indiana Solid Waste Regulations, 326 IAC 10

and 326 IAC 11. IDEM has not included these requirements in the Part 70 permit 

because IDEM, OAQ has determined that these conditions are not applicable 

requirements as defined by 326 IAC 2-7-1(6). 

(e) If, after issuance of this permit, it is determined that the permit is in nonconformance with 

an applicable requirement that applied to the source on the date of permit issuance,

IDEM, OAQ, shall immediately take steps to reopen and revise this permit and issue a

compliance order to the Permittee to ensure expeditious compliance with the applicable

requirement until the permit is reissued. The permit shield shall continue in effect so long

as the Permittee is in compliance with the compliance order. 

(f) No permit shield shall apply to any permit term or condition that is determined after 

issuance of this permit to have been based on erroneous information supplied in the

permit application. Erroneous information means information that the Permittee knew to 

be false, or in the exercise of reasonable care should have been known to be false, at the 

time the information was submitted. 

(g) Nothing in 326 IAC 2-7-15 or in this permit shall alter or affect the following: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 22 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(1) The provisions of Section 303 of the Clean Air Act (emergency orders), including 

the authority of the U.S. EPA under Section 303 of the Clean Air Act; 

(2) The liability of the Permittee for any violation of applicable requirements prior to

or at the time of this permit's issuance; 

(3) The applicable requirements of the acid rain program, consistent with Section 

408(a) of the Clean Air Act; and 

(4) The ability of U.S. EPA to obtain information from the Permittee under Section 

114 of the Clean Air Act. 

(h) This permit shield is not applicable to any change made under 326 IAC 2-7-20(b)(2) 

(Sections 502(b)(10) of the Clean Air Act changes) and 326 IAC 2-7-20(c)(2) (trading

based on State Implementation Plan (SIP) provisions). 

(i) This permit shield is not applicable to modifications eligible for group processing until 

after IDEM, OAQ, has issued the modifications. [326 IAC 2-7-12(c)(7)] 

(j) This permit shield is not applicable to minor Part 70 permit modifications until after IDEM,

OAQ, has issued the modification. [326 IAC 2-7-12(b)(7)] 

B.14 Prior Permits Superseded [326 IAC 2-1.1-9.5] 

(a) All terms and conditions of previous permits issued pursuant to permitting programs

approved into the state implementation plan have been either 

(1) incorporated as originally stated, 

(2) revised, or 

(3) deleted 

by this permit.

(b) All previous registrations and permits are superseded by this permit. 

B.15 Deviations from Permit Requirements and Conditions [326 IAC 2-7-5(3)(C)(ii)] 

(a) A deviation is an exceedance of a permit limitation or a failure to comply with a

requirement of the permit. 

(b) Deviations from any permit requirements, the probable cause of such deviations, and any

response steps or preventive measures taken shall be reported to:

Indiana Department of Environmental Management 

Compliance Data Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

using the attached Quarterly Deviation and Compliance Monitoring Report, or its 

equivalent. 

(c) A deviation caused by an emergency shall be included in the Quarterly Deviation and

Compliance Monitoring Report. (Additional requirements for emergencies are in Section

B - Emergency Provisions.) 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 23 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) A deviation required to be reported pursuant to an applicable requirement that exists

independent of this permit, shall be reported according to the schedule stated in the 

applicable requirement and does not need to be included in this report. 

B.16 Permit Modification, Reopening, Revocation and Reissuance, or Termination [326 IAC 2-7-5(6)

(C)] [326 IAC 2-7-8(a)] [326 IAC 2-7-9] 

(a) This permit may be modified, reopened, revoked and reissued, or terminated for cause.

The filing of a request by the Permittee for a Part 70 permit modification, revocation and 

reissuance, or termination, or of a notification of planned changes or anticipated noncompliance does not stay any condition of this permit. [326 IAC 2-7-5(6)(C)] The 

notification by the Permittee does require the certification by the “responsible official” as

defined by 326 IAC 2-7-1(34). 

(b) This permit shall be reopened and revised under any of the circumstances listed in IC 13-

15-7-2 or if IDEM, OAQ, determines any of the following: 

(1) That this permit contains a material mistake. 

(2) That inaccurate statements were made in establishing the emissions standards 

or other terms or conditions. 

(3) That this permit must be revised or revoked to assure compliance with an

applicable requirement. [326 IAC 2-7-9(a)(3)] 

(c) Proceedings by IDEM, OAQ, to reopen and revise this permit shall follow the same

procedures as apply to initial permit issuance and shall affect only those parts of this 

permit for which cause to reopen exists. Such reopening and revision shall be made as

expeditiously as practicable. [326 IAC 2-7-9(b)] 

(d) The reopening and revision of this permit, under 326 IAC 2-7-9(a), shall not be initiated 

before notice of such intent is provided to the Permittee by IDEM, OAQ, at least thirty 

(30) days in advance of the date this permit is to be reopened, except that IDEM, OAQ,

may provide a shorter time period in the case of an emergency. [326 IAC 2-7-9(c)] 

B.17 Permit Renewal [326 IAC 2-7-4] [326 IAC 2-7-3] 

(a) The application for renewal shall be submitted using the application form or forms 

prescribed by IDEM, OAQ, and shall include the information specified in 326 IAC 2-7-4. 

Such information shall be included in the application for each emission unit at this source,

except those emission units included on the trivial or insignificant activities list contained 

in 326 IAC 2-7-1(21) and 326 IAC 2-7-1(40). The renewal application does require the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

Request for renewal shall be submitted to: 

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue, 

 Indianapolis, Indiana 46204-2251 

(b) Timely Submittal of Permit Renewal [326 IAC 2-7-4(a)(1)(D)] 

(1) A timely renewal application is one that is: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 24 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(A) Submitted at least nine (9) months prior to the date of the expiration of 

this permit; and 

(B) If the date postmarked on the envelope or certified mail receipt, or affixed 

by the shipper on the private shipping receipt, is on or before the date it 

is due. If the document is submitted by any other means, it shall be

considered timely if received by IDEM, OAQ, on or before the date it is 

due. 

(2) If IDEM, OAQ, upon receiving a timely and complete permit application, fails to

issue or deny the permit renewal prior to the expiration date of this permit, this 

existing permit shall not expire and all terms and conditions shall continue in 

effect, including any permit shield provided in 326 IAC 2-7-15, until the renewal 

permit has been issued or denied. 

(c) Right to Operate After Application for Renewal [326 IAC 2-7-3] 

If the Permittee submits a timely and complete application for renewal of this permit, the 

source’s failure to have a permit is not a violation of 326 IAC 2-7 until IDEM, OAQ, takes 

final action denying the renewal application and all appeals of such denial have been 

exhausted, except that this protection shall cease to apply if, subsequent to the

completeness determination, the Permittee fails to submit by the deadline specified in 

writing by IDEM, OAQ, any additional information identified as being needed to process 

the application. 

(d) United States Environmental Protection Agency Authority [326 IAC 2-7-8(e)] 

If IDEM, OAQ, fails to act in a timely way on a Part 70 permit renewal, the U.S. EPA may 

invoke its authority under Section 505(e) of the Clean Air Act to terminate or revoke and 

reissue a Part 70 permit. 

B.18 Permit Amendment or Modification [326 IAC 2-7-11] [326 IAC 2-7-12] 

(a) Permit amendments and modifications are governed by the requirements of 326 IAC 2-7-

11 or 326 IAC 2-7-12 whenever the Permittee seeks to amend or modify this permit. 

(b) Any application requesting an amendment or modification of this permit shall be

submitted to:

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

 

Any such application shall be certified by the “responsible official” as defined by 326 IAC 

2-7-1(34). 

(c) The Permittee may implement administrative amendment changes addressed in the

request for an administrative amendment immediately upon submittal of the request. [326 

IAC 2-7-11(c)(3)] 

(d) No permit amendment or modification is required for the addition, operation or removal of

a nonroad engine, as defined in 40 CFR 89.2. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 25 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

B.19 Permit Revision Under Economic Incentives and Other Programs [326 IAC 2-7-5(8)] [326 IAC 2-

7-12(b)(2)] 

(a) No Part 70 permit revision shall be required under any approved economic incentives,

marketable Part 70 permits, emissions trading, and other similar programs or processes 

for changes that are provided for in a Part 70 permit. 

(b) Notwithstanding 326 IAC 2-7-12(b)(1) and 326 IAC 2-7-12(c)(1), minor Part 70 permit 

modification procedures may be used for Part 70 modifications involving the use of 

economic incentives, marketable Part 70 permits, emissions trading, and other similar 

approaches to the extent that such minor Part 70 permit modification procedures are

explicitly provided for in the applicable State Implementation Plan (SIP) or in applicable

requirements promulgated or approved by the U.S. EPA. 

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5] 

(a) The Permittee may make any change or changes at the source that are described in 326 

IAC 2-7-20(b), (c), or (e), without a prior permit revision, if each of the following conditions 

is met: 

(1) The changes are not modifications under any provision of Title I of the Clean Air 

Act; 

(2) Any preconstruction approval required by 326 IAC 2-7-10.5 has been obtained; 

(3) The changes do not result in emissions which exceed the emissions allowable

under this permit (whether expressed herein as a rate of emissions or in terms of 

total emissions); 

(4) The Permittee notifies the:

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

 

and 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

by written notification at least ten (10) days in advance of the proposed change. 

The Permittee shall attach every such notice to the Permittee's copy of this 

permit; and 

(5) The Permittee maintains records on-site which document, on a rolling five (5) 

year basis, all such changes and emissions trading that are subject to 326 IAC 2-

7-20(b), (c), or (e) and makes such records available, upon reasonable request, 

for public review. 

Such records shall consist of all information required to be submitted to IDEM, 

OAQ, in the notices specified in 326 IAC 2-7-20(b), (c)(1), and (e)(2). 

(b) The Permittee may make Section 502(b)(10) of the Clean Air Act changes (this term is

defined at 326 IAC 2-7-1(36)) without a permit revision, subject to the constraint of 326
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 26 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

IAC 2-7-20(a). For each such Section 502(b)(10) of the Clean Air Act change, the

required written notification shall include the following:

(1) A brief description of the change within the source; 

(2) The date on which the change will occur; 

(3) Any change in emissions; and 

(4) Any permit term or condition that is no longer applicable as a result of the 

change. 

The notification which shall be submitted is not considered an application form, report, or 

compliance certification. Therefore, the notifications required by subsections (a) and (b),

which shall be submitted by the Permittee, do not require the certification by the

“responsible official” as defined by 326 IAC 2-7-1(34). 

(c) Emission Trades [326 IAC 2-7-20(c)] 

The Permittee may trade increases and decreases in emissions in the source, where the 

applicable SIP provides for such emission trades without requiring a permit revision,

subject to the constraints of Section (a) of this condition and those in 326 IAC 2-7-20(c). 

(d) Alternative Operating Scenarios [326 IAC 2-7-20(d)] 

The Permittee may make changes at the source within the range of alternative operating

scenarios that are described in the terms and conditions of this permit in accordance with

326 IAC 2-7-5(9). No prior notification of IDEM, OAQ, or U.S. EPA is required.

B.21 Source Modification Requirement [326 IAC 2-7-10.5]

A modification, construction, or reconstruction is governed by 326 IAC 2 and 326 IAC 2-7-10.5.

B.22 Inspection and Entry [326 IAC 2-7-6] [IC 13-14-2-2] 

Upon presentation of proper identification cards, credentials, and other documents as may be

required by law, and subject to the Permittee’s right under all applicable laws and regulations to 

assert that the information collected by the agency is confidential and entitled to be treated as 

such, the Permittee shall allow IDEM, OAQ, U.S. EPA, or an authorized representative to 

perform the following: 

(a) Enter upon the Permittee's premises where a Part 70 source is located, or

emissions related activity is conducted, or where records must be kept under the

conditions of this permit; 

(b) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, have

access to and copy, any records that must be kept under the conditions of this permit; 

(c) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, inspect

any facilities/emission units, equipment (including monitoring and air pollution control

equipment), practices, or operations regulated or required under this permit; 

(d) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1, sample 

or monitor, substances or parameters for the purpose of assuring compliance with this 

permit or applicable requirements; and 

(e) As authorized by the Clean Air Act, IC 13-14-2-2, IC 13-17-3-2, and IC 13-30-3-1,utilizes 

any photographic, recording, testing, monitoring, or other equipment for the purpose of

assuring compliance with this permit or applicable requirements. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 27 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

B.23 Transfer of Ownership or Operational Control [326 IAC 2-7-11] 

(a) The Permittee must comply with the requirements of 326 IAC 2-7-11 whenever the

Permittee seeks to change the ownership or operational control of the source and no

other change in the permit is necessary. 

(b) Any application requesting an administrative amendment to reflect a change in the 

ownership or operational control of the source shall contain a written agreement

containing a specific date for transfer of permit responsibility, coverage and liability 

between the current and new Permittee. The application shall be submitted to: 

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue 

Indianapolis, Indiana 46204-2251 

 

The application which shall be submitted by the Permittee does not require the

certification by the "responsible official" as defined by 326 IAC 2-7-1(34). 

(c) The Permittee may implement administrative amendment changes addressed in the

request for an administrative amendment immediately upon submittal of the request. [326 

IAC 2-7-11(c)(3)] 

B.24 Annual Fee Payment [326 IAC 2-7-19] [326 IAC 2-7-5(7)] 

(a) The Permittee shall pay annual fees to IDEM, OAQ, within thirty (30) calendar days of

receipt of a billing. Pursuant to 326 IAC 2-7-19(b), if the Permittee does not receive a bill 

from IDEM, OAQ, the applicable fee is due April 1 of each year. 

(b) Except as provided in 326 IAC 2-7-19(e), failure to pay may result in administrative

enforcement action or revocation of this permit. 

(c) The Permittee may call the following telephone numbers: 1-800-451-6027 or 317-233-

4230 (ask for OAQ, Billing, Licensing, and Training Section), to determine the appropriate

permit fee. 

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314][326 IAC 1-1-6] 

For the purpose of submitting compliance certifications or establishing whether or not the 

Permittee has violated or is in violation of any emission limitation, standard, or rule in Title 326 of 

the Indiana Administrative Code, nothing in Title 326 of the Indiana Administrative Code shall 

preclude the use, including the exclusive use, of any credible evidence or information relevant to 

whether the Permittee would have been in compliance with the emission limitation, standard, or

rule, if the appropriate performance or compliance test procedure had been performed. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 28 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION C SOURCE OPERATION CONDITIONS 

Entire Source

Emission Limitations and Standards [326 IAC 2-7-5(1)]

C.1 Particulate Emission Limitations For Processes with Process Weight Rates Less Than One

Hundred (100) pounds per hour [326 IAC 6-3-2] 

Pursuant to 326 IAC 6-3-2(e)(2), particulate emissions from any process not exempt under 326

IAC 6-3-1(b) or (c) which has a maximum process weight rate less than 100 pounds per hour and

the methods in 326 IAC 6-3-2(b) through (d) do not apply shall not exceed 0.551 pounds per 

hour. 

C.2 Opacity [326 IAC 5-1] 

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary

Alternative Opacity Limitations), opacity shall meet the following, unless otherwise stated in this 

permit: 

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute 

averaging period, as determined in 326 IAC 5-1-4. 

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen

(15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, 

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a

continuous opacity monitor) in a six (6) hour period. 

C.3 Open Burning [326 IAC 4-1] [IC 13-17-9] 

The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-

1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in

accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1. 

326 IAC 4-1-3(a)(2)(A) and (B) are not federally enforceable. 

C.4 Incineration [326 IAC 4-2][326 IAC 9-1-2] 

The Permittee shall not operate an incinerator or incinerate any waste or refuse except as 

provided in 326 IAC 4-2 and 326 IAC 9-1-2. 326 IAC 9-1-2 is not federally enforceable. 

C.5 Fugitive Dust Emissions [326 IAC 6-4] 

The Permittee shall not allow fugitive dust to escape beyond the property line or boundaries of 

the property, right-of-way, or easement on which the source is located, in a manner that would 

violate 326 IAC 6-4 (Fugitive Dust Emissions). 326 IAC 6-4-2(4) is not federally enforceable. 

C.6 Operation of Equipment [326 IAC 2-7-6(6)] 

Except as otherwise provided by statute, rule or this permit, all air pollution control equipment 

listed in this permit and used to comply with an applicable requirement shall be operated at all 

times that the emission units vented to the control equipment are in operation. 

C.7 Stack Height [326 IAC 1-7]

The Permittee shall comply with the applicable provisions of 326 IAC 1-7 (Stack Height 

Provisions), for all exhaust stacks through which a potential (before controls) of twenty-five (25) 

tons per year or more of particulate matter or sulfur dioxide is emitted. The provisions of 326 IAC 

1-7-1(3), 326 IAC 1-7-2, 326 IAC 1-7-3(c) and (d), 326 IAC 1-7-4, and 326 IAC 1-7-5(a), (b) and

(d) are not federally enforceable. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 29 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

C.8 Asbestos Abatement Projects [326 IAC 14-10] [326 IAC 18] [40 CFR 61 Subpart M] 

(a) Notification requirements apply to each owner or operator. If the combined amount of

regulated asbestos containing material (RACM) to be stripped, removed or disturbed is at 

least 260 linear feet on pipes or 160 square feet on other facility components, or at least 

thirty-five (35) cubic feet on all facility components, then the notification requirements of 

326 IAC 14-10-3 are mandatory. All demolition projects require notification whether or

not asbestos is present. 

(b) The Permittee shall ensure that a written notification is sent on a form provided by the

Commissioner at least ten (10) working days before asbestos stripping or removal work 

or before demolition begins, per 326 IAC 14-10-3, and shall update such notice as

necessary, including, but not limited to the following: 

(1) When the amount of affected asbestos containing material increases or 

decreases by at least twenty percent (20%); or 

(2) If there is a change in the following: 

(A) Asbestos removal or demolition start date; 

(B) Removal or demolition contractor; or

(C) Waste disposal site. 

(c) The Permittee shall ensure that the notice is postmarked or delivered according to the

guidelines set forth in 326 IAC 14-10-3(2). 

(d) The notice to be submitted shall include the information enumerated in 326 IAC 14-10-

3(3). 

All required notifications shall be submitted to: 

Indiana Department of Environmental Management 

Asbestos Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

The notice shall include a signed certification from the owner or operator that the 

information provided in this notification is correct and that only Indiana licensed workers 

and project supervisors will be used to implement the asbestos removal project. The 

notifications do not require a certification by the "responsible official" as defined by 326

IAC 2-7-1(34). 

(e) Procedures for Asbestos Emission Control 

The Permittee shall comply with the applicable emission control procedures in 326 IAC 

14-10-4 and 40 CFR 61.145(c). Per 326 IAC 14-10-4 emission control requirements are

applicable for any removal or disturbance of RACM greater than three (3) linear feet on 

pipes or three (3) square feet on any other facility components or a total of at least 0.75

cubic feet on all facility components. 

(f) Demolition and renovation 

The Permittee shall thoroughly inspect the affected facility or part of the facility where the 

demolition or renovation will occur for the presence of asbestos pursuant to 40 CFR 

61.145(a). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 30 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(g) Indiana Accredited Asbestos Inspector 

The Permittee shall comply with 326 IAC 14-10-1(a) that requires the owner or operator, 

prior to a renovation/demolition, to use an Indiana Accredited Asbestos Inspector to

thoroughly inspect the affected portion of the facility for the presence of asbestos. The

requirement to use an Indiana Accredited Asbestos inspector is not federally enforceable. 

Testing Requirements [326 IAC 2-7-6(1)] 

C.9 Performance Testing [326 IAC 3-6] 

(a) All testing shall be performed according to the provisions of 326 IAC 3-6 (Source

Sampling Procedures), except as provided elsewhere in this permit, utilizing any 

applicable procedures and analysis methods specified in 40 CFR 51, 40 CFR 60, 40 CFR 

61, 40 CFR 63, 40 CFR 75, or other procedures approved by IDEM, OAQ. 

A test protocol, except as provided elsewhere in this permit, shall be submitted to: 

Indiana Department of Environmental Management 

Compliance Data Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

no later than thirty-five (35) days prior to the intended test date. The protocol submitted 

by the Permittee does not require certification by the “responsible official” as defined by 

326 IAC 2-7-1(34). 

(b) The Permittee shall notify IDEM, OAQ of the actual test date at least fourteen (14) days 

prior to the actual test date. The notification submitted by the Permittee does not require 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(c) All test reports must be received by IDEM, OAQ not later than forty-five (45) days after 

the completion of the testing. An extension may be granted by IDEM, OAQ, if the source

submits to IDEM, OAQ, a reasonable written explanation not later than five (5) days prior 

to the end of the initial forty-five (45) day period. The reports submitted by the Permittee

do require certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

Compliance Requirements [326 IAC 2-1.1-11]

C.10 Compliance Requirements [326 IAC 2-1.1-11] 

The commissioner may require stack testing, monitoring, or reporting at any time to assure

compliance with all applicable requirements by issuing an order under 326 IAC 2-1.1-11. Any 

monitoring or testing shall be performed in accordance with 326 IAC 3 or other methods approved

by the commissioner or the U.S. EPA. 

Compliance Monitoring Requirements [326 IAC 2-7-5(1)] [326 IAC 2-7-6(1)] 

C.11 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

Unless otherwise specified in this permit, all monitoring requirements not already legally required

shall be implemented within ninety (90) days of the original Part 70 permit issuance. If required

by Section D, the Permittee shall be responsible for installing any necessary equipment and

initiating any required monitoring related to that equipment. If due to circumstances beyond its

control, that equipment cannot be installed and operated within ninety (90) days, the Permittee

may extend the compliance schedule related to the equipment for an additional ninety (90) days 

provided the Permittee notifies: 

Indiana Department of Environmental Management 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 31 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

in writing, prior to the end of the initial ninety (90) day compliance schedule, with full justification 

of the reasons for the inability to meet this date. 

The notification which shall be submitted by the Permittee does require the certification by the 

“responsible official” as defined by 326 IAC 2-7-1(34). 

Unless otherwise specified in the approval for the new or modified facilities/emission units, compliance monitoring for new or modified facilities/emission units or facilities/emission units added or

modified through a source modification shall be implemented when operation begins. 

C.12 Maintenance of Continuous Opacity Monitoring Equipment [326 IAC 2-7-5(3)(A)(iii)] 

(a) The Permittee shall install, calibrate, maintain, and operate all necessary continuous opacity monitors (COMS) and related equipment. 

(b) In the event that a breakdown of the continuous opacity monitoring equipment occurs, a

record shall be made of the times and reasons of the breakdown and efforts made to 

correct the problem. 

(c) Whenever a continuous opacity monitor (COM) is malfunctioning or will be down for 

calibration, maintenance, or repairs for a period of one (1) hour or more, timely compliance with the applicable opacity limits shall be demonstrated by the following: 

(1) Visible emission (VE) notations shall be performed once per hour during daylight 

operations following the shutdown or malfunction of the COM. A trained employee

shall record whether emissions are normal or abnormal at the time of the reading. 

(A) A trained employee is an employee who has worked at the plant at least 

one (1) month and has been trained in the appearance and characteristics of normal visible emissions for that specific process. Permittee

may also use an independent contractor who has been trained in the 

appearance and characteristics of normal visible emissions for that 

specific process.

(B) If abnormal emissions are noted during two (2) consecutive VE notations, the Permittee shall begin opacity observations in accordance with

40 CFR Part 60, Appendix A, Method 9, within four (4) hours of the 

second abnormal VE notation. 

(C) VE notations may be discontinued once a COM is online or formal

Method 9 readings have been implemented. 

(2) If a COM is not online within twenty-four (24) hours of shutdown or malfunction of

the COM, the Permittee shall provide certified opacity reader(s), who may be

employees of the Permittee or independent contractors, to self-monitor opacity

from the stack. 

(A) Visible Emission readings shall be performed in accordance with 40 CFR 

Part 60, Appendix A, Method 9, for a minimum of five (5) consecutive six 

(6 minute averaging periods beginning not more than twenty-four (24)

hours after the start of the malfunction or down time. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 32 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(B) Method 9 opacity readings shall be repeated for a minimum of five (5) 

consecutive six (6) minute averaging periods at least once every four (4) 

hours during daylight operations, until such time that a COM is in

operation. 

(C) Method 9 opacity readings may be discontinued once COM is online. 

(3) All of the Method 9 opacity readings taken during this period shall be reported in

the Quarterly Reports Summary of Opacity Emissions. 

(d) Nothing in this permit, shall excuse the Permittee from complying with the requirements 

to operate a continuous opacity monitor system pursuant to 326 IAC 3-5 and 40 CFR 63, 

Subpart LLL. 

C.13 Monitoring Methods [326 IAC 3] [40 CFR 60] [40 CFR 63] 

Any monitoring or testing required by Section D of this permit shall be performed according to the 

provisions of 326 IAC 3, 40 CFR 60 Appendix A, 40 CFR 60 Appendix B, 40 CFR 63, or other

approved methods as specified in this permit. 

C.14 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] 

[326 IAC 2-7-6(1)] 

(a) Whenever a condition in this permit requires the measurement of pressure drop, voltage, 

current, or temperature across any part of the unit or its control device, the gauge or 

instrument employed shall have a scale such that the expected normal reading shall be

no less than twenty percent (20%) of full scale and be accurate within plus or minus two 

percent ( ±2%) of full scale reading. 

(b) The Permittee may request the IDEM, OAQ approve the use of a pressure gauge or 

other instrument that does not meet the above specifications provided the Permittee can 

demonstrate an alternative pressure gauge or other instrument specification will adequately ensure compliance with permit conditions requiring the measurement of pressure

drop or other parameters. 

Corrective Actions and Response Steps [326 IAC 2-7-5] [326 IAC 2-7-6]

C.15 Emergency Reduction Plans [326 IAC 1-5-2] [326 IAC 1-5-3] 

Pursuant to 326 IAC 1-5-2 (Emergency Reduction Plans; Submission): 

(a) The Permittee prepared and submitted written emergency reduction plans (ERPs) 

consistent with safe operating procedures on March 14, 2000. 

(b) If the ERP is disapproved by IDEM, OAQ, the Permittee shall have an additional thirty 

(30) days to resolve the differences and submit an approvable ERP. 

(c) Upon direct notification by IDEM, OAQ, that a specific air pollution episode level is in

effect, the Permittee shall immediately put into effect the actions stipulated in the 

approved ERP for the appropriate episode level. [326 IAC 1-5-3] 

C.16 Risk Management Plan [326 IAC 2-7-5(12)] [40 CFR 68 Subpart G]

If a regulated substance as defined in 40 CFR 68 is present at a source in more than a threshold 

quantity, the source must comply with the applicable requirements of 40 CFR 68. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 33 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports [326 IAC 2-7-5] 

[326 IAC 2-7-6] 

(a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each compliance monitoring condition of this permit. If a Permittee is required to have an Operation, Maintenance and Monitoring (OMM) Plan under 40 CFR 60/63, such plans shall be

deemed to satisfy the requirements for a CRP for those compliance monitoring conditions. A CRP shall be submitted to IDEM, OAQ upon request. The CRP shall be prepared within ninety (90) days after issuance of this permit by the Permittee, supplemented from time to time by the Permittee, maintained on site, and comprised of: 

(1) Reasonable response steps that may be implemented in the event that a

response step is needed pursuant to the requirements of Section D of this permit; 

and an expected time frame for taking reasonable response steps.

(2) If, at any time, the Permittee takes reasonable response steps that are not set 

forth in the Permittee=s current Compliance Response Plan or Operation, Maintenance and Monitoring (OMM) Plan and the Permittee documents such

response in accordance with subsection (e) below, the Permittee shall amend its 

Compliance Response Plan or Operation, Maintenance and Monitoring (OMM) 

Plan to include such response steps taken. 

The OMM Plan shall be submitted within the time frames specified by the applicable 40

CFR60/63 requirement. 

(b) For each compliance monitoring condition of this permit, reasonable response steps shall 

be taken when indicated by the provisions of that compliance monitoring condition as 

follows: 

(1) Reasonable response steps shall be taken as set forth in the Permittee=s current

Compliance Response Plan or Operation, Maintenance and Monitoring (OMM) 

Plan; or 

(2) If none of the reasonable response steps listed in the Compliance Response 

Plan or Operation, Maintenance and Monitoring (OMM) Plan is applicable or 

responsive to the excursion, the Permittee shall devise and implement additional 

response steps as expeditiously as practical. Taking such additional response

steps shall not be considered a deviation from this permit so long as the 

Permittee documents such response steps in accordance with this condition. 

(3) If the Permittee determines that additional response steps would necessitate that 

the emissions unit or control device be shut down, the IDEM, OAQ shall be

promptly notified of the expected date of the shut down, the status of the applicable compliance monitoring parameter with respect to normal, and the results of 

the actions taken up to the time of notification. 

(4) Failure to take reasonable response steps shall be considered deviation of the

permit.

(c) The Permittee is not required to take any further response steps for any of the following

reasons: 

(1) A false reading occurs due to the malfunction of the monitoring equipment and

prompt action was taken to correct the monitoring equipment. 

(2) The Permittee has determined that the compliance monitoring parameters established in the permit conditions are technically inappropriate, has previously 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 34 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

submitted a request for a minor permit modification to the permit, and such 

request has not been denied; or 

(3) An automatic measurement was taken when the process was not operating; or

(4) The process has already returned or is returning to operating within “normal” 

parameters and no response steps are required. 

(d) When implementing reasonable steps in response to a compliance monitoring condition, 

if the Permittee determines that an exceedance of an emission limitation has occurred,

the Permittee shall report such deviations pursuant to Section B-Deviations from Permit 

Requirements and Conditions. 

(e) The Permittee shall record all instances when, in accordance with Section D, response

steps are taken. In the event of an emergency, the provisions of 326 IAC 2-7-16 (Emergency Provisions) requiring prompt corrective action to mitigate emissions shall prevail. 

(f) Except as otherwise provided by a rule or provided specifically in Section D, all monitoring as required in Section D shall be performed when the emission unit is operating,

except for time necessary to perform quality assurance and maintenance activities. 

C.18 Actions Related to Noncompliance Demonstrated by a Stack Test [326 IAC 2-7-5][326 IAC 2-7-6] 

(a) When the results of a stack test performed in conformance with Section C - Performance 

Testing, of this permit exceed the level specified in any condition of this permit, the

Permittee shall take appropriate response actions. Upon request, the Permittee shall

submit a description of these response actions to IDEM, OAQ, within thirty (30) days of

receipt of the test results. The Permittee shall take appropriate action to minimize excess 

emissions from the affected facility/emissions unit while the response actions are being 

implemented. 

(b) A retest to demonstrate compliance shall be performed within one hundred twenty (120) 

days of receipt of the original test results. Should the Permittee demonstrate to IDEM, 

OAQ that retesting in one-hundred and twenty (120) days is not practicable, IDEM, OAQ

may extend the retesting deadline. 

(c) IDEM, OAQ reserves the authority to take any actions allowed under law in response to

noncompliant stack tests.

The response action documents submitted pursuant to this condition do require the certification

by the “responsible official” as defined by 326 IAC 2-7-1(34). 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

C.19 Emission Statement [326 IAC 2-7-5(3)(C)(iii)][326 IAC 2-7-5(7)][326 IAC 2-7-19(c)][326 IAC 2-6] 

(a) The Permittee shall submit an annual emission statement certified pursuant to the

requirements of 326 IAC 2-6, that must be received by July 1 of each year and must 

comply with the minimum requirements specified in 326 IAC 2-6-4. The annual emission

statement shall meet the following requirements: 

(1) Indicate estimated actual emissions of criteria pollutants from the source, in

compliance with 326 IAC 2-6 (Emission Reporting); 

(2) Indicate estimated actual emissions of regulated pollutants as defined by 326

IAC 2-7-1(32) (Regulated pollutant which is used only for purposes of Section 19

of this rule) from the source, for purposes of Part 70 fee assessment. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 35 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(b) The annual emission statement covers the twelve (12) consecutive month time period

starting January 1 and ending December 31. The annual emission statement must be 

submitted to:

Indiana Department of Environmental Management 

Technical Support and Modeling Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

The emission statement does require the certification by the “responsible official” as

defined by 326 IAC 2-7-1(34). 

(c) The annual emission statement required by this permit shall be considered timely if the

date postmarked on the envelope or certified mail receipt, or affixed by the shipper on the

private shipping receipt, is on or before the date it is due. If the document is submitted by 

any other means, it shall be considered timely if received by IDEM, OAQ, on or before

the date it is due. 

C.20 General Record Keeping Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-6] [326 IAC 2-2] 

(a) Records of all required monitoring data, reports and support information required by this 

permit shall be retained for a period of at least five (5) years from the date of monitoring 

sample, measurement, report, or application. These records shall be physically present 

or electronically accessible at the source location for a minimum of three (3) years. The 

records may be stored elsewhere for the remaining two (2) years as long as they are 

available upon request. If the Commissioner makes a request for records to the 

Permittee, the Permittee shall furnish the records to the Commissioner within a 

reasonable time. 

(b) Unless otherwise specified in this permit, all record keeping requirements not already 

legally required shall be implemented within ninety (90) days of permit issuance. 

(c) If there is a reasonable possibility that a “project” (as defined in 326 IAC 2-2-1(qq)) at an 

existing emissions unit, other than projects at a Clean Unit (or at a source with Plant-wide 

Applicability Limitation (PAL)), which is not part of a “major modification” (as defined in 

326 IAC 2-2-1(ee)) may result in significant emissions increase and the Permittee elects

to utilize the “projected actual emissions” (as defined in 326 IAC 2-2-1(rr)), the Permittee 

shall comply with the following: 

 

(1) Before beginning actual construction of the “project” (as defined in 326 IAC 2-2-

1(qq)) at an existing emissions unit, document and maintain the following 

records: 

(A) A description of the project. 

(B) Identification of any emissions unit whose emissions of a regulated new 

source review pollutant could be affected by the project. 

(C) A description of the applicability test used to determine that the project is 

not a major modification for any regulated NSR pollutant, including: 

(i) Baseline actual emissions;

(ii) Projected actual emissions; 

(iii) Amount of emissions excluded under section 326 IAC 2-2-

1(rr)(2)(A)(iii) and 

(iv) An explanation for why the amount was excluded, and any 

netting calculations, if applicable. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 36 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(2) Monitor the emissions of any regulated NSR pollutant that could increase as a 

result of the project and that is emitted by any existing emissions unit identified in 

(1)(B) above; and 

(3) Calculate and maintain a record of the annual emissions, in tons per year on a 

calendar year basis, for a period of five (5) years following resumption of regular 

operations after the change, or for a period of ten (10) years following resumption

of regular operation after the change if the project increases the design capacity 

of or the potential to emit that regulated NSR pollutant at the emissions unit. 

C.21 General Reporting Requirements [326 IAC 2-7-5(3)(C)] [326 IAC 2-1.1-11][326 IAC 2-2] 

(a) The Permittee shall submit the attached Quarterly Deviation and Compliance Monitoring

Report or its equivalent. Any deviation from permit requirements, the date(s) of each 

deviation, the cause of the deviation, and the response steps taken must be reported. 

This report shall be submitted within thirty (30) days of the end of the reporting period. 

The Quarterly Deviation and Compliance Monitoring Report shall include the certification 

by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(b) The report required in (a) of this condition and reports required by conditions in Section D 

of this permit shall be submitted to: 

Indiana Department of Environmental Management 

Compliance Data Section, Office of Air Quality 

100 North Senate Avenue

Indianapolis, Indiana 46204-2251 

(c) Unless otherwise specified in this permit, any notice, report, or other submission required 

by this permit shall be considered timely if the date postmarked on the envelope or 

certified mail receipt, or affixed by the shipper on the private shipping receipt, is on or 

before the date it is due. If the document is submitted by any other means, it shall be 

considered timely if received by IDEM, OAQ, on or before the date it is due. 

(d) Unless otherwise specified in this permit, all reports required in Section D of this permit 

shall be submitted within thirty (30) days of the end of the reporting period. All reports do

require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(e) The first report shall cover the period commencing on the date of issuance of this permit 

and ending on the last day of the reporting period. Reporting periods are based on 

calendar years, unless otherwise specified in this permit. For the purpose of this permit 

“calendar year” means the twelve (12) month period from January 1 to December 31 

inclusive. 

(f) If the Permittee is required to comply with the recordkeeping provisions of (c) in Section 

C – General Record Keeping Requirements for any “project” (as defined in 326 IAC 2-2-

1(qq)) at an existing emissions unit , and the project meets the following criteria, then the 

Permittee shall submit a report to IDEM, OAQ: 

(1) The annual emissions, in tons per year, from the project identified in (c)(1) 

Section C – General Record Keeping Requirements exceed the baseline actual 

emissions, as documented and maintained under Section C – General Record 

Keeping Requirements (C)(1)(c)(i), by a significant amount, as defined in 326 

IAC 2-2-1(xx), for that regulated NSR pollutant, and 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 37 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(2) The emissions differ from the preconstruction projection as documented and 

maintained under Section C – General Record Keeping Requirements 

(c)(1)(C)(ii). 

(g) The report for project at an existing emissions unit shall be submitted within sixty (60)

days after the end of the year and contain the following: 

(1) The name, address, and telephone number of the major stationary source. 

(2) The annual emissions calculated in accordance with (c)(2) and (3) in Section C – 

General Record Keeping Requirements. 

(3) The emissions calculated under the actual-to-projected actual test stated in 326 

IAC 2-2-2(d)(3). 

(4) Any other information that the Permittee wishes to include in the report. 

Reports required in this part shall be submitted to: 

Indiana Department of Environmental Management 

Air Compliance Section, Office of Air Quality 

100 North Senate Avenue

Indianapolis, Indiana 46204-2251 

(h) The Permittee shall make the information required to be documented and maintained in 

accordance with (c) in Section C – General Record Keeping Requirements available for 

review upon a request for inspection by IDEM, OAQ. The general public may request 

this information from IDEM, OAQ under 326 IAC 17.1. 

C.22 NESHAP Notification and Reporting Requirements [40 CFR Part 63, Subparts A and LLL] 

The Permittee shall comply with all reporting provisions specified in 40 CFR Part 63, Subpart LLL, 

and in particular: 

(a) The Permittee has submitted an initial notification in accordance with 40 CFR 63.9(b)

(Subpart A, General Provisions) on October 11, 1999 to U.S. EPA and IDEM. The 

Permittee provided the following information: 

(1) The name and address of the Permittee;

(2) The address (i.e., physical location) of the affected source; 

(3) An identification of the relevant standard, or other requirement, that is the basis 

of the notification and the source's compliance date; 

(4) A brief description of the nature, size, design, and method of operation of the

source, including its operating design capacity and an identification of each point 

of emission for each hazardous air pollutant, or if a definitive identification is not 

yet possible, a preliminary identification of each point of emission for each 

hazardous air pollutant; and 

(5) A statement of whether the affected source is a major source or an area source. 

(b) The Permittee shall submit a notification of performance tests, as required by 40 CFR 

63.7 and 40 CFR 63.9(e).
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 38 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(c) The Permittee shall submit a notification of opacity and visible emission observations as

required by 40 CFR 63.1349 in accordance with 40 CFR 63.6(h)(5) and 40 CFR 63.9(f). 

(d) The Permittee shall submit notification, as required by 40 CFR 63.9(g), of the date that 

continuous emission monitor performance evaluation required by 40 CFR 63.8(e) is 

scheduled to begin. 

(e) The Permittee shall submit notification of compliance status, as required by 40 CFR

63.9(h). 

(f) The notification(s) as required in this section shall be submitted to:

Indiana Department of Environmental Management 

Compliance Data Section, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251 

and 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Air Enforcement Branch - Indiana (AE-17J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Stratospheric Ozone Protection

C.23 Compliance with 40 CFR 82 and 326 IAC 22-1 

Pursuant to 40 CFR 82 (Protection of Stratospheric Ozone), Subpart F, except as provided for 

motor vehicle air conditioners in Subpart B, the Permittee shall comply with the standards for 

recycling and emissions reduction: 

(a) Persons opening appliances for maintenance, service, repair, or disposal must comply 

with the required practices pursuant to 40 CFR 82.156. 

(b) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to 40 CFR 

82.158. 

(c) Persons performing maintenance, service, repair, or disposal of appliances must be 

certified by an approved technician certification program pursuant to 40 CFR 82.161. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 39 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.1 FACILITY/EMISSION UNIT OPERATION CONDITIONS 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The quarry activities, as follows: 

(1) Drilling/blasting, hauling, handling and storage, identified as F01, commenced prior to 1971, with 

associated fugitive particulate matter (PM) emissions. 

The quarry material sizing facilities/emissions units, as follows: 

(1) One (1) primary crusher, identified as EU01, constructed in 1965, with a nominal rate of 975 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as QDC2, and exhausting to

one (1) stack, identified as S-QDC2. 

(2) One (1) surge bin and transfer system, identified as EU02, constructed in 1965, with a nominal rate 

of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as QDC3, and

exhausting to one (1) stack, identified as S-QDC3. 

(3) One (1) secondary crusher, identified as EU03, constructed in 1965, with a nominal rate of 975 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as QDC4, and exhausting to

one (1) stack, identified as S-QDC4. 

(4) One (1) tertiary crusher, identified as EU04, constructed in 1965, with a nominal rate of 975 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as QDC4, and exhausting to one

(1) stack, identified as S-QDC4. 

(5) One (1) north screen house, identified as EU05, constructed in 1965, with a nominal rate of 975 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as QDC5, and exhausting to

one (1) stack, identified as S-QDC5. 

(6) One (1) south screen house, identified as EU06, constructed in 1965, with a nominal rate of 975

tons per hour, with PM emissions controlled by one (1) baghouse, identified as QDC6, and 

exhausting to one (1) stack, identified as S-QDC6. 

(7) One (1) belt #7 to belt #8 conveyor transfer point, identified as EU07, constructed in 1965, with a 

nominal rate of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

QDC7, and exhausting to one (1) stack, identified as S-QDC7. 

(8) One (1) belt #8 to belt #9 conveyor transfer point, identified as EU08, constructed in 1965, with a 

nominal rate of 975 tons per hour, with PM emissions controlled by one (1) baghouse, identified as 

QDC8, and exhausting to one (1) stack, identified as S-QDC8. 

(9) One (1) belt #9 to belt #10 conveyor transfer point, identified as F02, constructed in 1965, with a

nominal rate of 975 tons per hour, using seasonal water suppression to control PM emissions, and

exhausting directly to the atmosphere. 

The cement kiln dust storage, disposal, mining, and handling facilities/emissions units, as follows: 

(1) One (1) cement kiln dust (CKD) bin, identified as EU24, constructed in 1959, with a nominal rate of 

100 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC7, and 

exhausting to one (1) stack, identified as S-KDC7. 

(2) One (1) CKD truck unloading system, identified as EU24A, constructed in 1959, with a nominal rate 

of 60 tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC7A, and 

exhausting to one (1) stack, identified as S-KDC7A. 

(3) One (1) CKD mixer, identified as EU24B, constructed in 1999, with a nominal rate of 104 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as KDC7B, and exhausting to 

one (1) stack, identified as S-KDC7B. 

(4) One (1) CKD truck loadout, identified as F07, constructed in 1999, with a nominal rate of 104 tons 

per hour, with PM emissions uncontrolled, and exhausting directly to the atmosphere. 

(5) CKD disposal, and mining facilities/emission units, identified as F05, constructed in 1999, with 

particulate matter emissions uncontrolled, and exhausting directly to the atmosphere. 

(The information describing the processes contained in this facility description box is descriptive information

and does not constitute enforceable conditions.)
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 40 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.1.1 Particulate [326 IAC 6-3-2]

(a) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the quarry material sizing facilities/ 

emissions units (EU01 through EU08 and F02) shall not exceed 77.3 pounds per hour

(total for all facilities/emission units combined) when operating at a process weight rate of 

975 tons per hour. 

The pounds per hour limitation was calculated with the following equation: 

Interpolation and extrapolation of the data for the process weight rate in excess of 60,000

pounds per hour shall be accomplished by use of the equation: 

E = 55.0 P0.11 - 40 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

When the process weight rate exceeds 200 tons per hour, the maximum allowable emissions may exceed the pounds per hour limitation calculated using the above referenced

equation, provided the concentration of particulate matter in the discharge gases to the 

atmosphere is less than 0.10 pounds per one thousand (1,000) pounds of gases.

(b) Pursuant to minor source modification 093-11313 issued November 9, 1999 for the CKD 

mixer (EU24B) and 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing 

Processes) for all units, the allowable PM emission rate from the cement kiln dust (CKD)

storage, disposal, mining, and handling facilities/emissions units (EU24, EU24A, and 

EU24B) shall not exceed 51.3 pounds per hour (total for all facilities/emission units

combined) when operating at a process weight rate of 100 tons per hour. 

The pounds per hour limitation was calculated with the following equation: 

Interpolation and extrapolation of the data for the process weight rate in excess of 60,000

pound per hour shall be accomplished by use of the equation: 

E = 55.0 P0.11 – 40 where: E = rate of emission in pounds per hour 

P = process weight rate in tons per hour 

D.1.2 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] [40 CFR 63, Subparts A and LLL] 

(a) None of the facilities/emission units listed in this section are subject to the requirements 

of the New Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F 

(Standards of Performance for Portland Cement Plants) because they are not affected

facilities that were constructed or modified after the applicability date of August 17, 1971. 

(b) None of the quarry facilities/emission units or quarry material sizing facilities/emission 

units, or the cement kiln dust storage, disposal, mining, and handling facilities/emission

units listed in this section are subject to the requirements of the National Emissions 

Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, 

because they are not affected facilities under this rule. 

D.1.3 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

(a) Pursuant to minor source modification 093-11313 issued November 9, 1999, and T093-

5990-00002, issued on December 30, 2002, and in order to render the requirements of

PSD not applicable, the following conditions shall apply: 

(1) The combined PM emissions from the CKD mixer (EU24B), the CKD disposal 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 41 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

and mining facilities (F05), and the truck loadout (F07) shall not exceed 5.68 

pounds per hour. 

 (2) The combined PM10 emissions from the CKD mixer (EU24B), the CKD disposal

and mining facilities (F05), and the truck loadout (F07) shall not exceed 3.40 

pounds per hour. 

These limitations will result in PM and PM10 emissions of less than 25 and 15 tons per

year, respectively. Therefore, the requirements of 326 IAC 2-2 (PSD) do not apply. 

(b) Pursuant to Significant Permit Modification 093-16851-00002 issued on July 11, 2003,

and Significant Permit Modification 093-18649-00002 issued in 2004, in order to render 

the requirements of 326 IAC 2-2 (PSD) not applicable, the following conditions shall apply

upon startup of either preheater Kilns #1 or #2: 

(1) The Primary crusher (EU01), the Surge Bin and Transfer System (EU02), the 

Secondary Crusher (EU03), the Tertiary Crusher (EU04), the North Screen

House (EU05), the South Screen House (EU06), the Belt #7 to Belt #8 Conveyor 

Transfer Point (EU07) and the Belt #8 to Belt #9 Conveyor transfer point (EU08)

shall each be limited to 2,500 hours of operation per 12 consecutive month

period with compliance determined at the end of each month. 

(2) PM and PM10 emissions from baghouse QDC2 controlling the Primary Crusher 

(EU01) shall each not exceed 0.68 pounds per hour.

(3) PM and PM10 emissions from baghouse QDC3 controlling the Quarry Surge Bin 

and Transfer System (EU02) shall each not exceed 0.50 pounds per hour. 

(4) PM and PM10 emissions from baghouse QDC7 controlling Belt #7 to Belt #8

Conveyor Transfer Point (EU07) shall each not exceed 0.44 pounds per hour. 

(5) PM and PM10 emissions from baghouse QDC8 controlling Belt #8 to Belt #9

Conveyor Transfer Point (EU08) shall each not exceed 0.44 pounds per hour. 

(6) PM and PM10 emissions from baghouse QDC4 controlling the Secondary Crusher

(EU03) and the Tertiary Crusher (EU04) shall each not exceed 0.72 pounds per

hour. 

(7) PM and PM10 emissions from baghouse QDC6 controlling the South Screen

House (EU06) shall each not exceed 0.79 pounds per hour. 

(8) PM and PM10 emissions from baghouse QDC5 controlling the North Screen

House (EU05) shall each not exceed 0.18 pounds per hour. 

(9) PM and PM10 emissions from baghouse KDC7 controlling the Cement Kiln Dust 

Bin (EU24) shall each not exceed 0.89 pounds per hour. 

(10) PM and PM10 emissions from baghouse KDC7A controlling the CKD Truck 

Unloading System (EU24A) shall each not exceed 0.36 pounds per hour. 

(11) PM and PM10 emissions from baghouse KDC7B controlling Mixer (EU24B) shall

each not exceed 0.54 pounds per hour.

These limits ensure that the PM and PM10 emissions increase from the modification

permitted in Significant Permit Modification 093-16851-00002 issued on July 11, 2003,
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 42 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

and Significant Permit Modification 093-18649-00002 issued in 2004 will not exceed 25 

and 15 tons per year, respectively. Therefore, the requirements of 326 IAC 2-2 (PSD) 

are not applicable to these modifications.

D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for the control devices listed in this section. 

Compliance Determination Requirements

D.1.5 Particulate Control 

Pursuant to minor source modification 093-11313 issued November 9, 1999, for the CKD mixer 

(EU24B), and in order for all units to comply with Conditions D.1.1 and D.1.3, except as otherwise 

provided by statute, rule or this permit, each baghouse listed in this section for particulate control 

shall be in operation at all times when its associated facility/emissions unit is in operation. 

D.1.6 Testing requirement [326 IAC 2-1.1-11]

To verify compliance with condition D.1.3(b), the permittee shall, within 60 days after achieving 

the maximum capacity but no later than 180 days after startup of preheater Kiln #1 (EU15) and

Kiln #2 (EU16), perform PM and PM10 testing on the Secondary Crusher (EU03), the Tertiary 

Crusher (EU04), and the North Screen House (EU05) utilizing methods as approved by the 

Commissioner. Testing shall be conducted in accordance with Section C- Performance Testing.

All associated facilities exhausting to a single stack must all be operating when determining

compliance with the limit. PM10 includes filterable and condensible PM10. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.1.7 Visible Emissions Notations 

Visible emission notations of all the baghouse stack exhausts shall be performed once per shift

during normal daylight operations. A trained employee shall record whether emissions are normal 

or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process. 

(d) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an abnormal emission is observed or when visible 

emissions are observed crossing the property line. Failure to take response steps in

accordance with Section C - Compliance Response Plan - Preparation, Implementation, 

Records, and Reports, shall be considered a violation of this permit. 

D.1.8 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse listed in this

section, at least once per shift when the associated facility/emissions unit is in operation. When

for any one reading, the pressure drop across a baghouse is outside the normal range of 1.0 and 

8.0 inches of water or a range established during the latest stack test, the Permittee shall take

reasonable response steps in accordance with Section C - Compliance Response Plan - Prepara-
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 43 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

tion, Implementation, Records, and Reports. A pressure reading that is outside the above

mentioned range is not a deviation from this permit. Failure to take response steps in accordance

with Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit.

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.1.9 Baghouse Inspections 

An inspection shall be performed each calendar quarter of all bags controlling the processes

listed in this section when venting to the atmosphere. A baghouse inspection shall be performed 

within three months of redirecting vents to the atmosphere and every three months thereafter. 

Inspections are optional when venting to the indoors. Inspections required by this condition shall 

not be performed in consecutive months. All defective bags shall be replaced. 

D.1.10 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 

(b) For single compartment baghouses, if failure is indicated by a significant drop in the 

baghouse’s pressure readings with abnormal visible emissions or the failure is indicated

by an opacity violation, or if bag failure is determined by other means, such as gas 

temperatures, flow rates, air infiltration, leaks, dust traces, or triboflows, then failed units 

and the associated process will be shut down immediately until the failed units have been

repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this 

permit (Section B - Emergency Provisions). 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.11 Record Keeping Requirements 

(a) To document compliance with Condition D.1.3(b)(1), the Permittee shall maintain records 

of the Primary crusher (EU01), the Surge Bin and Transfer System (EU02), the Secondary Crusher (EU03), the Tertiary Crusher (EU04), the North Screen House (EU05), the 

South Screen House (EU06), the Belt #7 to Belt #8 Conveyor Transfer Point (EU07) and 

the Belt #8 to Belt #9 Conveyor transfer point (EU08) operating hours. 

(b) To document compliance with Condition D.1.7, the Permittee shall maintain records of

visible emission notations of the baghouse stack exhausts once per shift. 

(c) To document compliance with Condition D.1.8, the Permittee shall maintain records of

the differential static pressure of each baghouse once per shift. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 44 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) To document compliance with Condition D.1.9, the Permittee shall maintain records of

the results of the inspections required under Condition D.1.9. 

(e) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.1.12 Reporting Requirements 

A quarterly summary of the information to document compliance with Condition D.1.3(b)(1) shall

be submitted to the address listed in Section C - General Reporting Requirements, using the 

reporting forms located at the end of this permit, or the equivalent, within thirty (30) days after the

end of the quarter being reported. The report submitted by the Permittee does require the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 45 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.2 FACILITY/EMISSION UNIT OPERATION CONDITIONS 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The raw material handling and storage facilities/emissions units, as follows: 

(1) A conveying system to transport raw material to storage, identified as EU09, constructed in

1960, with a nominal rate of 200 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as RMDC1 and exhausting to one (1) stack, identified as S-RMDC1. 

(2) One (1) shale crusher, identified as EU10, constructed in 1961, with a nominal rate of 200 tons 

per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC2, and

exhausting to one (1) stack, identified as S-RMDC2. 

(3) One (1) material storage building, identified as F03, constructed in 1959-1960, with fugitive

emissions from various conveyors and storage piles controlled by partial enclosure and

exhausting directly to the atmosphere. 

(4) One (1) coal unloading building, identified as F08, constructed in 1960, with particulate matter 

emissions controlled by partial enclosure and exhausting directly to the atmosphere. 

(5) One (1) coal pile, identified as F04, constructed prior to 1971, with particulate matter emissions 

uncontrolled, and exhausting directly to the atmosphere. 

(6) Raw material stockpiles collectively, identified as F09, storage commencing prior to 1971, used

for temporary storage of various feed materials, including gypsum, foundry sand, mill scale, 

and slag, with particulate matter emissions uncontrolled, and exhausting to the atmosphere. 

Kiln #1 and Kiln #2 Alternative Fuel Delivery Systems as follows: 

 

(1) One (1) Kiln #1 alternative fuel delivery system, identified as F19, consisting of a partially 

enclosed hopper exhausting to the atmosphere and a series of totally enclosed conveyors, with 

a nominal throughput of 87,600 tons per year. 

 

(2) One (1) Kiln #2 alternative fuel delivery system, identified as F20, consisting of a partially 

enclosed hopper exhausting to the atmosphere and a series of totally enclosed conveyors, with 

a nominal throughput of 87,600 tons per year. 

The raw mill facilities/emissions units, as follows: 

(1) One (1) raw mill #1, identified as EU11, constructed in 1961, with a nominal rate of 100 tons 

per hour and including a natural gas-fired burner, identified as EU11A, with a maximum heat

input capacity of 20 million British thermal units (MMBtu) per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC3, and exhausting to one (1) stack, identified 

as S-RMDC3.

(2) One (1) raw mill #2, identified as EU12, constructed in 1961, with a nominal rate of 100 tons 

per hour and including a natural gas-fired burner, identified as EU12A, with a maximum heat

input capacity of 20 million British thermal units (MMBtu) per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC4, and exhausting to one (1) stack, identified 

as S-RMDC4.

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 46 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Insignificant Activities, as follows: 

(1) Three (3) coal mills, with nominal rates of 5, 6, and 6 tons per hour, with particulate matter

emissions controlled by total enclosure, and exhausting to the kilns. 

(2) One coal feeder conveyor and one coal unloading conveyor, with nominal rates of 250 tons per 

hour and 260 tons per hour, respectively, constructed prior to August 17, 1971, with particulate 

matter emissions controlled by total enclosure. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

Emission Limitations and Standards [326 IAC 2-7-5(1)]

D.2.1 Particulate [326 IAC 6-3-2]

(a) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the raw material conveying system

(EU09) shall not exceed 58.5 pounds per hour when operating at a process weight rate of

200 tons per hour. 

(b) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the shale crusher (EU10) shall not

exceed 58.5 pounds per hour when operating at a process weight rate of 200 tons per 

hour. 

(c) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the raw mill #1 (EU11 and EU11A) 

shall not exceed 51.3 pounds per hour when operating at a process weight rate of 100

tons per hour. 

(d) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing 

 Processes), the allowable particulate emission rate from the raw mill #2 (EU12 and 

 EU12A) shall not exceed 51.3 pounds per hour when operating at a process weight rate 

 of 100 tons per hour. 

The pounds per hour limitations for (a) through (d) were calculated with the following equation: 

Interpolation and extrapolation of the data for the process weight rate in excess of 60,000 pounds 

per hour shall be accomplished by use of the equation:

E = 55.0 P0.11 - 40 where E = rate of emission in pounds per hour; and 

 P = process weight rate in tons per hour 

(e) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing 

Processes), the allowable particulate emissions rate from the Kiln #1 alternative fuel 

delivery system (F19), shall not exceed 19.2 pounds per hour when operating at a

process weight rate of 10 tons per hour. 

 

(f) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing

 Processes), the allowable particulate emissions rate from the Kiln #2 alternative fuel 

 delivery system (F20), shall not exceed 19.2 pounds per hour when operating at a 

 process weight rate of 10 tons per hour. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 47 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

The pounds per hour limitations for (e) and (f) were calculated with the following equation: 

Interpolation of the data for the process weight rate up to 60,000 pounds per hour shall be 

accomplished by use of the equation: 

E = 4.1 P0.67 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

D.2.2 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by 

reference in 326 IAC 20-1, apply to the material storage building (F03), the raw mills (EU11, 

EU11A, EU12 and EU12A), and each conveying system transfer point associated with the Kiln #1

and Kiln #2 alternative fuel delivery systems (F19) and (F20) described in this section except

when otherwise specified in 40 CFR Part 63, Subpart LLL. 

D.2.3 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

 Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), the visible emissions 

from the material storage building (F03), each of the raw mills (EU11, EU11A, EU12 and EU12A), 

and each conveying system transfer point associated with the Kiln #1 and Kiln #2 alternative fuel

delivery systems (F19) and (F20) shall each not exceed ten percent (10%) opacity. 

D.2.4 Sulfur Dioxide (SO2) [326 IAC 7-1.1] [326 IAC 7-2-1] 

Pursuant to minor source modification 093-10597 issued March 1, 1999, the two (2) natural gasfired burners (EU11A and EU12A) shall combust only natural gas. Therefore, the requirements of 

326 IAC 7-1.1 (Sulfur Dioxide Emission Limitations) will not apply to the natural gas-fired burners 

(EU11A and EU12A). 

D.2.5 NSPS for Portland Cement Plants [326 IAC 12] [40 CFR 60, Subpart F] 

Pursuant to minor source modification 093-10597 issued March 1, 1999, the natural gas-fired

burners (EU11A and EU12A) were not to operate at the same time as the then existing 37 million

Btu per hour coal-fired stoker. Therefore, the addition of the natural gas-fired burners did not 

result in an emissions increase for the system and the requirements of 326 IAC 12 (New Source

Performance Standards) and 40 CFR Part 60, Subparts A and F, will not apply to the raw mills 

(EU11 and EU12) or the natural gas-fired burners (EU11A and EU12A) as a result of this 

modification. 

D.2.6 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] [40 CFR 63, Subparts A and

LLL] [40 CFR 60, Subpart Y] 

(a) The raw material handling and storage facilities/emission units (EU09, EU10, F03, F04,

F08, and F09) are not subject to the requirements of the New Source Performance 

Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for 

Portland Cement Plants) because they were constructed prior to the applicability date of

August 17, 1971 and have not been modified since the applicability date, or they are not 

considered affected facilities under the rule. 

(b) The conveying system (EU09), the shale crusher (EU10), the coal pile (F04), the coal 

unloading building (F08), the raw material stockpiles (F09), and the insignificant coal mills 

are not subject to the requirements of the National Emissions Standards for Hazardous 

Air Pollutants (NESHAP) 40 CFR 63 Subparts A and LLL, because these facilities/

emission units are not affected facilities under the regulation. 

(c) The coal mills and the coal conveyors are not subject to the requirements of the New

Source Performance Standard, 326 IAC 12 and 40 CFR 60, Subpart Y because they are 

completely enclosed and there is no discharge to the atmosphere from the coal mills. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 48 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) The coal pile (F04) is not subject to the requirements of the New Source Performance

Standard, 326 IAC 12 and 40 CFR 60, Subpart Y because it is not considered an affected

facility under the regulation. Additionally, facilities/emission units EU09, EU10, F03, F08,

F09, EU11A, EU12A, EU11, EU12, the three insignificant coal mills, the coal feeder 

conveyor and the coal unloading conveyor are not subject to the requirements of the New 

Source Performance Standard, 326 IAC 12 and 40 CFR 60, Subpart Y because they are 

not affected facilities under the rule or they were not constructed or modified after 

October 24, 1974. 

D.2.7 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

Pursuant to Significant Permit Modification 093-16851-00002 issued in 2003, in order to render

the requirements of 326 IAC 2-2 (PSD) not applicable to this modification, the following conditions

shall apply upon startup of either preheater Kilns #1 or #2: 

(a) The Conveying System to Transport Raw Material to Storage (EU09) and the Shale

Crusher (EU10) shall each be limited to 2,500 hours of operation per 12 consecutive

month period with compliance determined at the end of each month.

(b) PM and PM10 emissions from baghouse RMDC1 controlling the Conveying System to 

Transport Raw Material to Storage (EU09) shall each not exceed 0.27 pounds per hour. 

(c) PM and PM10 emissions from baghouse RMDC2 controlling the Shale Crusher (EU10) 

shall each not exceed 1.44 pounds per hour. 

(d) PM and PM10 emissions from baghouse RMDC3 controlling Raw Mill #1 (EU11) shall

each not exceed 3.50 pounds per hour.

(e) PM and PM10 emissions from baghouse RMDC4 controlling Raw Mill #2 (EU12) shall

each not exceed 4.51 pounds per hour.

These limits ensure that the PM and PM10 emissions increase from the modification permitted in

Significant Permit Modification 093-16851-00002 issued on July 11, 2003, and Significant Permit 

Modification 093-18649-00002 issued in 2004 will not exceed 25 and 15 tons per year, 

respectively. Therefore, the requirements of 326 IAC 2-2 (PSD) are not applicable to these 

modifications.

D.2.8 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for the control devices listed in this section. If the Operations and

Maintenance Plan required by Condition D.2.11 is developed in accordance with Section B - 

Preventive Maintenance Plan, then once the Operations and Maintenance Plan has been

developed, it shall satisfy this condition. 

Compliance Determination Requirements 

D.2.9 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] [40 CFR 63, Subpart LLL] 

(a) Within 180 days after June 14, 2002, which is the compliance date for the Portland

Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the limit established in Condition D.2.3 for the material storage building (F03) 

and the raw mills (EU11, EU11A, EU12, EU12A), by conducting a test in accordance with 

40 CFR 63.1349 and Method 9 of 40 CFR Part 60, Appendix A. Testing shall be

conducted in accordance with Section C - Performance Testing. 

(b) Within 60 days after achieving maximum capacity but no later than 180 days after startup

of preheater Kilns #1 and #2, in order to demonstrate compliance with Condition D.2.1
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 49 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

and D.2.7, the Permittee shall perform PM and PM10 testing on the Raw Mills (EU11, 

EU11A, EU12 and EU12A) utilizing methods as approved by the Commissioner. These 

tests shall be repeated at least once every five (5) years from the date of this valid compliance demonstration. Testing shall be conducted in accordance with Section C- Performance Testing. All associated facilities exhausting to a single stack must all be 

operating when determining compliance with the limit. PM10 includes filterable and 

condensible PM10. 

(c) Within 180 days after start up of each of the alternative fuel delivery systems (F19 and 

F20), the Permittee shall demonstrate initial compliance with the limit established in 

Condition D.2.3 by conducting a test in accordance with 40 CFR 63.1349(b)(2) and 

Method 9 of 40 CFR Part 60, Appendix A. Testing shall be conducted in accordance with

Section C - Performance Testing. 

Pursuant to 40 CFR 63.1349(c), the Method 9 performance tests required in paragraphs (a) and 

(c) above shall each be repeated at least once every five years from the date of the valid 

compliance demonstration. 

D.2.10 Particulate Control 

Except as otherwise provided by statute, rule or this permit, each baghouse listed in this section 

for particulate control shall be in operation at all times when its associated facility/emissions unit 

is in operation, in order to comply with Conditions D.2.1, D.2.3 and D.2.7. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.2.11 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

(a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a

written operations and maintenance plan for the material storage building (F03) and each

of the raw mills (EU11, EU11A, EU12 and EU12A) by June 14, 2002, which is the compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP)

from the Portland Cement Manufacturing Industry; and for the conveyor transfer points 

associated with the Kiln #1 alternative fuel delivery system (F19) and the conveyor

transfer points associated with the Kiln #2 alternative fuel delivery system (F20), upon 

startup of operations. 

 

 The plan shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected sources and

associated air pollution control device(s) in order to meet the emissions limit in

Condition D.2.3; and 

(2) Procedures to be used to periodically monitor the material storage building (F03), 

and the conveyor transfer points associated with the Kiln #1 and Kiln #2

alternative fuel delivery systems (F19 and F20), which are subject to opacity 

standards under 40 CFR 63.1348. Such procedures must include the following

provisions: 

(A) The Permittee shall conduct a monthly 1-minute visible emissions test of

each affected source in accordance with 40 CFR 60, Appendix A, Method

22. The test must be conducted while the affected source is in operation.

(B) If no visible emissions are observed in six consecutive monthly tests for 

any affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible

emissions are observed during any semi-annual test, the Permittee shall
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 50 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

resume testing of that affected source on a monthly basis and maintain

that schedule until no visible emissions are observed in six consecutive

monthly tests. 

(C) If no visible emissions are observed during the semi-annual test for any

affected source, the Permittee may decrease the frequency of testing

from semi-annually to annually for that affected source. If visible emissions are observed during any annual test, the Permittee shall resume

testing of that affected source on a monthly basis and maintain that 

schedule until no visible emissions are observed in six consecutive

monthly tests. 

(D) If visible emissions are observed during any Method 22 test, the Permittee

must conduct a 6-minute test of opacity in accordance with 40 CFR 60, 

Appendix A, Method 9. The Method 9 test must begin within one hour of 

any observation of visible emissions. 

(3) Corrective actions to be taken when required by paragraph (b). 

The requirement to conduct Method 22 visible emissions monitoring under Section 

D.2.11(a)(2) above, shall not apply to any totally enclosed conveying system 

transfer point that is operated and maintained as total enclosures on a continuing

basis in accordance with the facility operations and maintenance plan, regardless of 

the location of the transfer point. “Totally enclosed conveying system transfer point” 

shall mean a conveying system transfer point that is enclosed on all sides, top, and

bottom. 

If any partially enclosed or unenclosed conveying system transfer point is located 

in a building, the Permittee shall have the option to conduct a Method 22 visible 

emissions monitoring test according to the requirements of paragraphs (a)(2)(A) 

through (D) of this section for each such conveying system transfer point located 

within the building, or for the building itself, according with the paragraph below. 

If visible emissions from a building are monitored, the requirements of 

paragraphs (a)(2)(A) through (D) of this section apply to the monitoring of the 

building, and the Permittee shall also test visible emissions from each side, roof 

and vent of the building for at least 1 minute. The test must be conducted under 

normal operating conditions. 

Failure to comply with any provision of the operations and maintenance plan 

shall be a violation of the standard. The contents of the operations and 

maintenance plan are not included in this permit and may be modified by the 

Permittee without modification or amendment of this permit. 

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 

2002, the Permittee shall monitor opacity from the raw mills (EU11, EU11A, 

EU12 and EU12A) by conducting daily visual emissions observations of the mill 

sweep and air separator particulate matter control devices (PMCDs), in 

accordance with the procedures of 40 CFR 60, Appendix A, Method 22. The 

Method 22 test shall be conducted while the affected source is operating at 

representative performance conditions. The duration of the Method 22 test shall 

be six minutes. If visible emissions are observed during any Method 22 visible 

emissions test, the Permittee must: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 51 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(1) Initiate, within one (1) hour, the corrective actions specified in the site 

specific operations and maintenance plan developed in accordance with 

40 CFR §§ 63.1350(a)(1) and (a)(2). 

(2) Within twenty-four (24) hours of the end of the Method 22 test in which 

visible emissions were observed, conduct a follow-up Method 22 test of 

each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are observed during the 

follow-up Method 22 test from any stack from which visible emissions 

were observed during the previous Method 22 test, conduct a visual

opacity test of each stack from which visible emissions were observed 

during the follow-up Method 22 test in accordance with 40 CFR Part 60, 

Appendix A, Method 9. The duration of the Method 9 test shall be thirty 

minutes. 

D.2.12 Visible Emissions Notations 

Visible emission notations of all of the baghouse stack exhausts controlling the raw mills (EU11, 

EU11A, EU12 and EU12A), shall be performed once per day during normal daylight operations.

Visible emission notations of all other baghouse stack exhausts shall be performed once per shift

during normal daylight operations. A trained employee shall record whether emissions from the

stacks are normal or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process.

(d) On days that the NESHAP monitoring required in Condition D.2.11 is performed, the

Permittee may use those results to satisfy the requirements of this condition for the units 

subject to the NESHAP. 

(e) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an abnormal emission is observed. Failure to take response 

steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit.

D.2.13 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse controlling the 

raw mills (EU11, EU11A, EU12 and EU12A) at least once per day when the associated facility/

emissions unit is in operation. The Permittee shall record the total static pressure drop across all 

other baghouses listed in this section, at least once per shift when the associated facility/ 

emissions unit is in operation. When for any one reading, the pressure drop across each baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range established during

the latest stack test, the Permittee shall take reasonable response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. A 

pressure reading that is outside the above mentioned range is not a deviation from this permit. 

Failure to take response steps in accordance with Section C - Compliance Response Plan - 

Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 52 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.2.14 Baghouse Inspections 

An inspection shall be performed each calendar quarter of all bags controlling the processes

listed in this section when venting to the atmosphere. A baghouse inspection shall be performed 

within three months of redirecting vents to the atmosphere and every three months thereafter. 

Inspections are optional when venting to the indoors. Inspections required by this condition shall 

not be performed in consecutive months. All defective bags shall be replaced. 

D.2.15 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the

Compliance Response Plan shall be initiated. For any failure with corresponding

response steps and timetable not described in the Compliance Response Plan, response 

steps shall be devised within eight (8) business hours of discovery of the failure and shall 

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit.

(b) For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with abnormal visible emissions or the failure is indicated by

an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the

associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency

and the Permittee satisfies the requirements of the emergency provisions of this permit 

(Section B - Emergency Provisions). 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.16 Record Keeping Requirements 

(a) To document compliance with Condition D.2.12, the Permittee shall maintain records of

visible emission notations of the baghouse stack exhausts controlling the raw mills 

(EU11, EU11A, EU12 and EU12A) once per day and all other baghouse stack exhausts

once per shift. 

(b) To document compliance with Condition D.2.13, the Permittee shall maintain records of

the differential static pressure of each baghouse controlling the raw mills (EU11, EU11A, 

EU12 and EU12A) once per day and all other baghouses once per shift. 

(c) To document compliance with Condition D.2.14, the Permittee shall maintain records of

the results of the inspections required under Condition D.2.14. 

(d) On and after the NESHAP 40 CFR 63, Subpart LLL compliance date, to document 

compliance with the NESHAP, the Permittee shall maintain all records required by 40

CFR 63.1355. These records include the following: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 53 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(1) The Permittee shall maintain files of all information (including all reports and

notifications) required by 40 CFR 60.1355(a) recorded in a form suitable and 

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(e) To document compliance with Condition D.2.7(a), the Permittee shall maintain records of

the Conveying System to Transport Raw Material to Storage (EU09) and the Shale 

Crusher (EU10) operating hours. 

(f) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.2.17 Reporting Requirements 

(a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

report the information required by 40 CFR 63.1354, including, but not limited to the 

following: 

(1) The plan required by Condition D.2.11 for the material storage building (F03) and 

each of the raw mills (EU11, EU11A, EU12 and EU12A) shall be submitted to

IDEM, OAQ and U.S. EPA by June 14, 2002, which is the compliance date for 

the National Emission Standards for Hazardous Air Pollutants (NESHAP) from

the Portland Cement Manufacturing Industry; and the plans required for the 

conveyor transfer points associated with the Kiln #1 alternative fuel delivery 

system (F19) and the conveyor transfer points associated with the Kiln #2

alternative fuel delivery system (F20) shall be submitted to IDEM, OAQ and U.S. 

EPA upon startup of each operation. 

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of 

performance tests as part of the notification of compliance status, required in

Section C - NESHAP Notification and Reporting Requirements. 

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results

from tests required by 40 CFR 63.1349. 

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a

startup, shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified in the 

source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), 

the Permittee shall state such information in a semiannual report. Reports shall 

only be required if a startup, shutdown, or malfunction occurred during the 

reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring

system performance reports. 

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee

during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, and 

malfunction plan, the Permittee shall report the actions taken for that event within
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 54 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

2 working days after commencing actions inconsistent with the plan, by 

telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile

(FAX) transmission at (317) 233-6865. The immediate report shall be followed

by a letter within 7 working days after the end of the event, certified by the 

Permittee, explaining the circumstances of the event, the reasons for not 

following the startup, shutdown, and malfunction plan, and whether any excess 

emissions and/or parameter monitoring exceedances are believed to have 

occurred. 

(b) In addition to being submitted to the address listed in Section C - General Reporting

Requirements, all reports and the operations and maintenance plan submitted pursuant 

to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following 

address: 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Pursuant to 40 CFR 63.10(d), the reports submitted by the Permittee shall include the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(c) A quarterly summary of the information to document compliance with Condition D.2.7(a)

shall be submitted to the address listed in Section C - General Reporting Requirements, 

using the reporting forms located at the end of this permit, or the equivalent, within thirty 

(30) days after the end of the quarter being reported. The report submitted by the

Permittee does require the certification by the “responsible official” as defined by 326 IAC 

2-7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 55 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.3 FACILITY/EMISSION UNIT OPERATION CONDITIONS

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The raw mill storage facilities/emissions units, as follows:

(1) Blending bins, identified as EU13, constructed in 1961, with a combined nominal rate of 250 tons

per hour, with PM emissions controlled by two (2) baghouses, identified as RMDC5 and RMDC6,

and each exhausting to separate stacks, identified as S-RMDC5 and S-RMDC6, respectively. 

(2) Kiln supply silos, identified as EU14, constructed in 1961, with a combined nominal rate of 250 tons

per hour, with PM emissions controlled by two (2) baghouses, identified as RMDC7 and RMDC8,

and each exhausting to separate stacks, identified as S-RMDC7 and S-RMDC8, respectively. 

(3) One (1) kiln feed bin #1, identified as EU18, constructed in 1959, with a nominal rate of 66 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as KDC1, and exhausting to one 

(1) stack, identified as S-KDC1. 

(4) One (1) kiln feed bin #2, identified as EU20, constructed in 1959, with a nominal rate of 66 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as KDC3, and exhausting to one 

(1) stack, identified as S-KDC3. 

(5) One (1) kiln feed bin #3, identified as EU22, constructed in 1974, with a nominal rate of 73 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as KDC5, and exhausting to one 

(1) stack, identified as S-KDC5. 

The clinker handling facilities/emissions units, as follows: 

(1) One (1) south storage drag, identified as EU25, constructed in 1974, with a nominal rate of 120 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as FDC1, and exhausting to

one (1) stack, identified as S-FDC1. 

(2) One (1) north clinker tower, identified as EU26a, constructed in 1959, with a nominal rate of 120

tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC2, and 

exhausting to one (1) stack, identified as S-FDC2. 

(3) One (1) North storage drag, identified as EU26b, with a nominal rate of 120 tons per hour, with PM 

emissions controlled by one (1) baghouse, identified as FDC2, constructed in 1959, and exhausting 

to one (1) stack, identified as S-FDC2. 

(4) One (1) scrap bin clinker ladder, identified as EU26c, constructed in 1993, with a nominal rate of 

120 tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC2, and 

exhausting to one (1) stack, identified as S-FDC2. 

(5) One (1) south clinker tower, identified as EU27, constructed in 1974, with a nominal rate of 120 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as FDC3, and exhausting to

one (1) stack, identified as S-FDC3. 

(6) One (1) hot spout clinker ladder, identified as EU28, constructed in 1993, with a nominal rate of 120 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC4, and 

exhausting to one (1) stack, identified as S-FDC4. 

(7) One (1) pan clinker conveyor, identified as EU29, constructed in 1979, with a nominal rate of 120

tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC5, and 

exhausting to one (1) stack, identified as S-FDC5. 

(8) One (1) east clinker ladder, identified as EU30, constructed in 1993, with a nominal rate of 120 tons 

per hour, with PM emissions controlled by one (1) baghouse, identified as FDC6, and exhausting to

one (1) stack, identified as S-FDC6. 

(9) One (1) roll crusher, identified as EU31, constructed in 1987, with a nominal rate of 240 tons per 

hour, with PM emissions controlled by one (1) baghouse, identified as FDC7, and exhausting to one 

(1) stack, identified as S-FDC7. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 56 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Note: The scrap bin clinker ladder (EU26c), the hot spout clinker ladder (EU28), and the east clinker ladder 

(EU30) are not emission units; they are flaps which are used to reduce the drop heights from the North

clinker tower, the south clinker tower, and the north storage drag, respectively, which reduce particulate

emissions.

The finish mill facilities/emissions units, as follows: 

(1) One (1) finish mill #1 with associated feed bin, identified as EU32, constructed in 1959, with a

nominal rate of 37 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

FDC8, and exhausting to one (1) stack, identified as S-FDC8. 

(2) One (1) finish mill #2 with associated feed bin, identified as EU33, constructed in 1959, with a

nominal rate of 37 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

FDC9, and exhausting to one (1) stack, identified as S-FDC9. 

(3) One (1) finish mill #3 with associated feed bin, identified as EU34, constructed in 1959, with a

nominal rate of 37 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

FDC10, and exhausting to one (1) stack, identified as S-FDC10. 

(4) One (1) finish mill #4 with associated feed bin, identified as EU35, constructed in 1974, with a

nominal rate of 50 tons per hour, with PM emissions controlled by one (1) baghouse, identified as

FDC11, and exhausting to one (1) stack, identified as S-FDC11. 

(5) One (1) finish mill #4 separator, identified as EU36, constructed in 1989, with a nominal rate of 50

tons per hour, with PM emissions controlled by one (1) baghouse, identified as FDC12, and 

exhausting to one (1) stack, identified as S-FDC12. 

(6) One (1) lime bin, identified as EU38, constructed in 1993, with a nominal rate of 6 tons per hour, 

with PM emissions controlled by one (1) baghouse, identified as FDC14, and exhausting to one (1) 

stack, identified as S-FDC14.

The finish material storage facilities/emissions units, as follows: 

(1) One (1) surge bin, identified as EU37, with a nominal rate of 35 tons per hour, with PM emissions 

controlled by one (1) baghouse, identified as FDC13, and exhausting to one (1) stack, identified as

S-FDC13. 

(2) A north and south silo operation consisting of thirty (30) storage silos, identified as EU39A and

EU39B, constructed in 1959, with a nominal rate of 60 tons per hour, with PM emissions controlled

by two (2) baghouses, identified as SDC1 and SDC2, and exhausting to two (2) stacks, identified as

S-SDC1 and S-SDC2, respectively. 

(3) A silo transfer system, identified as EU40A and EU40B, constructed in 1959, with a nominal rate of

300 tons per hour, with PM emissions controlled by two (2) baghouses, identified as SDC3 and

SDC4, and exhausting to two (2) stacks, identified as S-SDC3 and S-SDC4, respectively 

The bulk loading and packaging facilities/emissions units, as follows: 

(1) One (1) east truck loadout bin, identified as EU41, constructed in 1959, with a nominal rate of 450 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC5, and

exhausting to one (1) stack, identified as S-SDC5. 

(2) One (1) east truck vaculoader, identified as EU42, constructed in 1959, with a nominal rate of 450

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC6, and

exhausting to one (1) stack, identified as S-SDC6. 

(3) One (1) west truck loadout bin, identified as EU43, constructed in 1959, with a nominal rate of 450

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC7, and

exhausting to one (1) stack, identified as S-SDC7. 

(4) One (1) west truck vaculoader, identified as EU44, constructed in 1959, with a nominal rate of 450 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC8, and

exhausting to one (1) stack, identified as S-SDC8. 

(The information describing the processes contained in this facility description box is descriptive information

and does not constitute enforceable conditions.) 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 57 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

 

(5) One (1) truck loadout station, identified as F06, constructed in 1959, with a nominal rate of 30 tons 

per hour, and exhausting directly to the atmosphere. 

(6) One (1) railroad loadout bin, identified as EU45, constructed in 1959, with a nominal rate of 240 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as SDC9, and 

 exhausting to one (1) stack, identified as S-SDC9. 

(7) One (1) articuloader, identified as EU46, constructed in 1959, with a nominal rate of 240 tons

per hour, with PM emissions controlled by one (1) baghouse, identified as SDC10, and 

exhausting to one (1) stack, identified as S-SDC10. 

(8) One (1) packing machine, identified as EU47, constructed in 1984, with a nominal rate of 40 tons

per hour, with PM emissions controlled by two (2) baghouses, identified as SDC11 and SDC12, and

exhausting to two (2) stacks, identified as S-SDC11 and S-SDC12, respectively. 

(The information describing the processes contained in this facility description box is descriptive information

and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.3.1 Particulate [326 IAC 6-3-2]

(a) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from raw mill blending and kiln supply storage

facilities/emissions units (EU13 and EU14) shall not exceed 61.0 pounds per hour (total

for both EU13 and EU14) when operating at a process weight rate of 250 tons per hour. 

(b) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the kiln feed bin #1 (EU18) shall not exceed 

47.2 pounds per hour when operating at a process weight rate of 66 tons per hour. 

(c) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the kiln feed bin #2 (EU20) shall not exceed 

47.2 pounds per hour when operating at a process weight rate of 66 tons per hour. 

(d) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the kiln feed bin #3 (EU22) shall not exceed 

48.2 pounds per hour when operating at a process weight rate of 73 tons per hour. 

(e) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the south storage drag (EU25) shall not 

exceed 53.1 pounds per hour when operating at a process weight rate of 120 tons per 

hour. 

(f) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the north clinker tower (EU26a) shall not 

exceed 53.1 pounds per hour when operating at a process weight rate of 120 tons per 

hour. 

(g) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the north storage drag (EU26b) shall not 

exceed 53.1 pounds per hour when operating at a process weight rate of 120 tons per 

hour. 

(h) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the south clinker tower (EU27) shall not 

exceed 53.1 pounds per hour when operating at a process weight rate of 120 tons per 

hour. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 58 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(i) Pursuant to 326 IAC 6-3-2 (Particulate Emissions Limitation for Manufacturing Processes), the allowable PM emission rate from the pan clinker conveyor (EU29) shall not

exceed 53.1 pounds per hour when operating at a process weight rate of 120 tons per 

hour. 

(j) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the roll crusher (EU31) shall not 

exceed 60.5 pounds per hour when operating at a process weight rate of 240 tons per 

hour. 

(k) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from finish mill #1 and associated feed bin 

(EU32) shall not exceed 42 pounds per hour when operating at a process weight rate of 

37 tons per hour. 

(l) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from finish mill #2 and associated feed bin 

(EU33) shall not exceed 42 pounds per hour when operating at a process weight rate of 

37 tons per hour. 

(m) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from finish mill #3 and associated feed bin 

(EU34) shall not exceed 42 pounds per hour when operating at a process weight rate of 

37 tons per hour. 

(n) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from finish mill #4, associated feed bin

and separator (EU35 and EU36) shall not exceed 45 pounds per hour (total for all

facilities/emission units) when operating at a process weight rate of 50 tons per hour. 

(o) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the lime bin (EU38) shall not exceed

13.6 pounds per hour when operating at a process weight rate of 6 tons per hour. 

(p) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the surge bin (EU37) shall not 

exceed 41.3 pounds per hour when operating at a process weight rate of 35 tons per 

hour. 

(q) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the north silo operation (EU39A) 

shall not exceed 46.3 pounds per hour when operating at a process weight rate of 60 

tons per hour. 

(r) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the south silo operation (EU39B) 

shall not exceed 46.3 pounds per hour when operating at a process weight rate of 60 

tons per hour. 

(s) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the silo transfer system (EU40A) 

shall not exceed 63 pounds per hour when operating at a process weight rate of 300 tons 

per hour. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 59 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(t) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the silo transfer system (EU40B) 

shall not exceed 63 pounds per hour when operating at a process weight rate of 300 tons 

per hour. 

(u) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the east truck loadout bin and vaculoader (EU41 and EU42) shall not exceed 67.7 pounds per hour (total for all

facilities/emission units) when operating at a process weight rate of 450 tons per hour. 

(v) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the west truck loadout bin and vaculoader (EU43 and EU44) shall not exceed 67.7 pounds per hour (total for all facilities/

emission units) when operating at a process weight rate of 450 tons per hour. 

(w) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the railroad loadout bin and articuloader (EU45 and EU46) shall not exceed 60.5 pounds per hour (total for all facilities/

emission units) when operating at a process weight rate of 240 tons per hour. 

(x) Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the allowable particulate emission rate from the packing machine (EU47) shall

not exceed 43 pounds per hour when operating at a process weight rate of 40 tons per 

hour. 

The pounds per hour limitation for the lime bin (EU38) was calculated with the following equation: 

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

hour shall be accomplished by use of the equation: 

E = 4.10 P 0.67 where E = rate of emission in pounds per hour and 

 P = process weight rate in tons per hour 

The pounds per hour limitations for all the other processes were calculated with the following 

equation: 

Interpolation and extrapolation of the data for the process weight rate in excess of 60,000 pounds 

per hour shall be accomplished by use of the equation:

E = 55.0 P0.11 - 40 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

When the process weight rate exceeds 200 tons per hour, the maximum allowable emissions 

may exceed the pound per hour limit calculated using the above-referenced equation, provided 

the concentration of particulate matter in the discharge gases to the atmosphere is less than 0.10 

pounds per one thousand (1,000) pounds of gases. 

D.3.2 Supersession of a Condition in a Previously Issued Construction Permit [326 IAC 12] [40 CFR 60, 

Subpart F] 

CP 093-2770-00002, issued March 3, 1993 stated that pursuant to the New Source Performance 

Standards, 326 IAC 12 (40 CFR 60.60 through 60.66) Subpart F, (Standards of Performance for

Portland Cement Plants), visible emissions from the hydrated lime feed system (EU38) and the

clinker ladders (EU26c, EU28, and EU30) shall not exceed 10% opacity (40 CFR 60.62(c)). 

However, upon further review, it has been determined that the three clinker ladders (EU28, EU30,

and EU26c) which were permitted in CP 093-2770-00002, were updates to existing drop points, 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 60 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

which reduced emissions. Therefore, they were not “modifications” as defined in 40 CFR 60.14. 

Consequently, 40 CFR 60, Subpart F does not apply to the clinker ladders (EU28, EU30, and

EU26c). 

D.3.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

On and after June 14, 2002, the provisions of 40 CFR Part 63, Subpart A - General Provisions, 

which are incorporated by reference in 326 IAC 20-1, apply to the raw mill storage facilities/

emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated

with the clinker handling facilities/emission units (EU25, EU26a, EU26b, EU27, and EU29) the roll

crusher (EU31), the finish mill facilities/emission units (EU32 through EU36 and EU38), and the 

finish material storage and bulk loading and packaging facilities/emission units (EU37, EU39 

through EU47, and F06) described in this section except when otherwise specified in 40 CFR 

Part 63, Subpart LLL. 

D.3.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), on and after June 14,

2002, which is the compliance date for the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, the visible emissions

from each of the raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), 

the conveyor transfer points associated with the clinker handling facilities/emission units (EU25,

EU26a, EU26b, EU27, and EU29), the roll crusher (EU31), the finish mill facilities/emission units 

(EU32 through EU36, and EU38), and the finish material storage and bulk loading and packaging

facilities/emission units (EU37, EU39 through EU47, and F06) shall not exceed ten percent (10%) 

opacity. 

D.3.5 Determinations of Nonapplicability [40 CFR 60, Subparts A and F] [40 CFR 63, Subparts A and LLL] 

(a) The raw mill storage facilities/emissions units (EU13, EU14, EU18, and EU20), the finish 

mill facilities/emission units (EU32, EU33, and EU34), the clinker handling facilities 

(EU25, EU26a, EU26b, EU26c, EU28, EU29, and EU30), and the finish material storage 

and bulk loading and packaging facilities/emission units (EU37, EU39A, EU39B, EU40A, 

EU40B, EU41 through EU46 and F06) are not subject to the requirements of the New 

Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of 

Performance for Portland Cement Plants) because they are not affected facilities under 

the rule or they were not constructed or modified after the applicability date of August 17,

1971. 

(b) The clinker handling facilities/emission units (EU26c, EU28, and EU30) are not subject to 

the requirements of the National Emission Standards for Hazardous Air Pollutants 

(NESHAP), 40 CFR 63, Subparts A and LLL (NESHAP from the Portland Cement Manufacturing Industry) because they are not affected facilities under the regulation. 

D.3.6 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

(a) In order to render the requirements of PSD not applicable, to the Permittee’s: 1979 pan

clinker conveyor modification; 1984 packing machine modification; 1987 roll crusher 

modification; 1989 finish mill #4 separator modification; and 1993 lime bin modification, 

respectively, the following conditions shall apply: 

(1) The PM emissions from the baghouse FDC5 controlling the pan clinker conveyor 

(EU29) shall not exceed 5.68 pounds per hour. 

(2) The PM emissions from the baghouses SDC11 and SDC 12 controlling the 

packing machine (EU47) shall not exceed 5.68 pounds per hour. 

(3) The PM emissions from the baghouse FDC7 controlling the roll crusher (EU31)

shall not exceed 5.68 pounds per hour. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 61 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(4) The PM emissions from the baghouse FDC12 controlling the finish mill #4 

separator (EU36) shall not exceed 5.68 pounds per hour. 

 (5) The PM10 emissions from the baghouse FDC12 controlling the finish mill #4

separator (EU36) shall not exceed 3.40 pounds per hour. 

(6) The PM emissions from the baghouse FDC14 controlling the lime bin (EU38) 

shall not exceed 5.68 pounds per hour. 

 (7) The PM10 emissions from the baghouse FDC14 controlling the lime bin (EU38)

shall not exceed 3.40 pounds per hour. 

These limits will ensure that the PM and PM10 emissions increases from the modifications 

above do not exceed 25 and 15 tons per year, respectively. Therefore, the requirements 

of 326 IAC 2-2, PSD, are not applicable.

(b) Pursuant to Significant Permit Modification 093-16851-00002 issued on July 11, 2003,

and Significant Permit Modification 093-18649-00002 issued in 2004, in order to render 

the requirements of 326 IAC 2-2 (PSD) not applicable, the following conditions shall apply

upon startup of either preheater Kilns #1 or #2: 

(1) PM and PM10 emissions from Blending Bins (EU13) shall each not exceed 1.06

pounds per hour while exhausting from baghouse RMDC5 and shall not exceed

0.53 pounds per hour while exhausting from baghouse RMDC6. 

(2) PM and PM10 emissions from Kiln Supply Silos (EU14) shall each not exceed

1.06 pounds per hour while exhausting from baghouse RMDC7 and shall not 

exceed 0.53 pounds per hour while exhausting from baghouse RMDC8. 

(3) PM and PM10 emissions from baghouse KDC1 controlling Kiln #1 Feed Bin 

(EU18) shall each not exceed 0.49 pounds per hour.

(4) PM and PM10 emissions from baghouse KDC3 controlling Kiln #2 Feed Bin 

(EU20) shall each not exceed 0.49 pounds per hour.

(5) PM and PM10 emissions from baghouse FDC1 controlling South Storage Drag

(EU25) shall each not exceed 0.47 pounds per hour.

(6) The Finish Mill Surge Bin (EU37) shall be limited to 1,500 hours of operation per 

12 consecutive month period with compliance determined at the end of each

month. 

(7) PM and PM10 emissions from baghouse FDC2 controlling North Clinker Tower 

(EU26A) shall each not exceed 1.76 pounds per hour. 

(8) PM and PM10 emissions from baghouse FDC3 controlling South Clinker Tower

(EU27) shall each not exceed 1.68 pounds per hour.

(9) PM and PM10 emissions from baghouse FDC4 controlling Hot Spout Clinker 

Ladder (EU28) shall each not exceed 1.76 pounds per hour. 

(10) PM and PM10 emissions from baghouse FDC5 controlling Pan Conveyor (EU29)

shall each not exceed 0.85 pounds per hour. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 62 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(11) PM and PM10 emissions from baghouse FDC6 controlling East Clinker Ladder 

(EU30) shall each not exceed 1.21 pounds per hour.

(12) PM and PM10 emissions from baghouse FDC7 controlling Roll Crusher (EU31)

shall each not exceed 1.84 pounds per hour. 

(13) PM and PM10 emissions from baghouse FDC8, controlling Finish Mill #1 (EU32),

shall each not exceed 1.42 pounds per hour. 

(14) PM and PM10 emissions from baghouse FDC9 controlling Finish Mill #2 (EU33) 

shall each not exceed 1.42 pounds per hour. 

(15) PM and PM10 emissions from baghouse FDC10 controlling Finish Mill #3 (EU34) 

shall each not exceed 1.42 pounds per hour. 

(16) PM and PM10 emissions from baghouse FDC11 controlling Finish Mill #4 (EU35) 

shall each not exceed 0.64 pounds per hour. 

(17) PM and PM10 emissions from baghouse FDC12 controlling Finish Mill #4

Separator (EU36) shall each not exceed 3.27 pounds per hour. 

(18) The Lime Bin (EU38) shall be limited 2,500 hours of operation per 12

consecutive month period with compliance determined at the end of each month.

(19) PM and PM10 emissions from baghouse FDC14 controlling Lime Bin (EU38) shall

each not exceed 0.22 pounds per hour.

(20) PM and PM10 emissions from baghouse FDC13 controlling Finish Mill Surge Bin 

(EU37) shall each not exceed 0.49 pounds per hour.

(21) PM and PM10 emissions from baghouse SDC1 controlling North Silo Operation

(EU39A) shall each not exceed 1.77 pounds per hour. 

(22) PM and PM10 emissions from baghouse SDC2 controlling South Silo Operation 

(EU39B) shall each not exceed 1.77 pounds per hour. 

(23) PM and PM10 emissions from baghouse SDC3 controlling Silo Transfer - East 

(EU40A) shall each not exceed 0.57 pounds per hour. 

(24) PM and PM10 emissions from baghouse SDC4 controlling Silo Transfer - West 

(EU40B) shall each not exceed 0.57 pounds per hour. 

(25) PM and PM10 emissions from baghouse SDC5 controlling East Truck Loadout 

Bin (EU41) shall each not exceed 0.43 pounds per hour. 

(26) PM and PM10 emissions from baghouse SDC7 controlling West Truck Loadout

Bin (EU43) shall each not exceed 0.43 pounds per hour. 

(27) PM and PM10 emissions from baghouse SDC6 controlling East Vaculoader 

(EU42) shall each not exceed 0.22 pounds per hour.

(28) PM and PM10 emissions from baghouse SDC8 controlling West Vaculoader 

(EU44) shall each not exceed 0.22 pounds per hour.
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 63 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(29) The Railroad Loadout Bin (EU45) and the Articuloader (EU46) shall be limited to 

2,000 hours of operation per 12 consecutive month period with compliance determined at the end of each month. 

(30) PM and PM10 emissions from baghouse SDC9 controlling Railroad Loadout Bin 

(EU45) shall each not exceed 0.71 pounds per hour.

(31) PM and PM10 emissions from baghouse SDC10 controlling Articuloader (EU46) 

shall each not exceed 0.21 pounds per hour. 

(32) The Packing Machine (EU47) shall be limited to 5,500 hours of operation per 12

consecutive month period with compliance determined at the end of each month.

(33) PM and PM10 emissions from baghouse SDC11 and baghouse SDC12

controlling Packing Machine (EU14) shall each not exceed 0.92 pounds per hour. 

These limits will ensure that the PM and PM10 emissions increase from the modification

permitted in Significant Permit Modification 093-16851-00002 issued on July 11, 2003,

and Significant Permit Modification 093- 18649-00002 issued in 2004 will not exceed 25

and 15 tons per year, respectively. Therefore, the requirements of 326 IAC 2-2 (PSD) 

are not applicable to these modifications.

D.3.7 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for all control devices listed in this section. If the Operations and Maintenance Plan required by Condition D.3.10 is developed in accordance with Section B - Preventive 

Maintenance Plan, then once the Operations and Maintenance Plan has been developed, it shall 

satisfy this condition. 

Compliance Determination Requirements

D.3.8 Testing Requirements [326 IAC 2-7-6(1),(6)] [40 CFR 63, Subpart LLL] [326 IAC 2-1.1-11] 

(a) Within 180 days after June 14, 2002, which is the compliance date for the Portland

Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the limit established in Condition D.3.4 by conducting a test in accordance with

40 CFR 63.1349 and Method 9 of 40 CFR Part 60, Appendix A. Testing shall be conducted in accordance with Section C - Performance Testing. These tests shall be

repeated at least once every five (5) years from the date of this valid compliance demonstration. 

(b) Within 60 days after achieving maximum capacity but no later than 180 days after startup

of preheater Kilns #1 and #2, in order to demonstrate compliance with Condition D.3.1(k), 

(l), (m), (n), and D.3.6, the Permittee shall perform PM and PM10 testing on the Finish mill

#1 (EU32), Finish mill #2 (EU33), Finish mill #3 (EU34), Finish Mill #4 (EU35) and the 

finish mill #4 separator (EU36). These tests shall be conducted utilizing methods as 

approved by the Commissioner. These tests shall be repeated at least once every five

(5) years from the date of this valid compliance demonstration. Testing shall be conducted in accordance with Section C- Performance Testing. PM10 includes filterable and

condensible PM10. All associated facilities exhausting to a single stack must all be 

operating when determining compliance with the limit. 

D.3.9 Particulate Control 

Pursuant to CP093-2770 issued March 3, 1993, for the three clinker ladders (EU26c, EU28 and

EU30 and the lime bin (EU38), and in order for all units to comply with Conditions D.3.1, D.3.4

and D.3.6, except as otherwise provided by statute, rule or this permit, each baghouse listed in
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 64 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

this section for particulate control shall be in operation at all times when its associated

facility/emissions unit is in operation. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.3.10 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

(a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a

written operations and maintenance plan for the raw mill storage facilities/emissions units 

(EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the

clinker handling facilities/emission units (EU25, EU26a, EU26b, EU27, and EU29), the 

clinker handling facility/emission unit described as the roll crusher (EU31), the finish mill

facilities/emission units (EU32 through EU36 and EU38), and the finish material storage

and bulk loading and packaging facilities/emission units (EU37, EU39 through EU47, and

F06) by June 14, 2002, which is the compliance date for the National Emission Standards

for Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing

Industry. The plan shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected sources and

associated air pollution control device(s) in order to meet the emissions limit in

Condition D.3.4; and 

(2) Procedures to be used to periodically monitor the affected facilities, which are

subject to opacity standards under 40 CFR 63.1348. Such procedures must 

include the following provisions: 

(A) The Permittee shall conduct a monthly 1-minute visible emissions test on

each stack exhaust (S-RMDC5 through S-RMDC8, S-KDC1, S-KDC3, SKDC5, S-FDC1 through S-FDC3, S-FDC5, S-FDC7, S-FDC13, and SSDC1 through S-SDC12) associated with the raw mill storage facilities/

emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor

transfer points associated with the clinker handling facilities/emission units

(EU25, EU26a, EU26b, EU27, and EU29), the clinker handling facility/

emission unit described as the roll crusher (EU31), the finish material storage

facilities/emission units (EU37, EU39A, EU39B, EU40A, and EU40B), 

the bulk loading and packaging facilities/emission units (EU41 through

EU47), the lime bin (EU38), and the truck loadout station (F06) in

accordance with 40 CFR 60, Appendix A, Method 22. The test must be

conducted while the source is in operation. 

(B) If no visible emissions are observed in six consecutive monthly tests for 

any affected source, the Permittee may decrease the frequency of testing from monthly to semi-annually for that affected source. If visible

emissions are observed during any semi-annual test, the Permittee shall

resume testing of that affected source on a monthly basis and maintain

that schedule until no visible emissions are observed in six consecutive 

monthly tests. 

(C) If no visible emissions are observed during the semi-annual test for any

affected source, the Permittee may decrease the frequency of testing from 

semi-annually to annually for that affected source. If visible emissions 

are observed during any annual test, the Permittee shall resume testing

of that affected source on a monthly basis and maintain that schedule 

until no visible emissions are observed in six consecutive monthly tests.

(D) If visible emissions are observed during any Method 22 test, the Permittee
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 65 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

must conduct a 6-minute test of opacity in accordance with 40 CFR 60, 

Appendix A, Method 9. The Method 9 test must begin within one hour of 

any observation of visible emissions. 

(3) Corrective actions to be taken when required by paragraph (b). 

Failure to comply with any provision of the operations and maintenance plan shall be a

violation of the standard. The contents of the operations and maintenance plan are not 

included in this permit and may be modified by the Permittee without modification or

amendment of this permit. 

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, the

Permittee shall monitor opacity from the finish mills (EU32 through EU36) by conducting

daily visual emissions observations of the mill sweep and air separator particulate matter 

control devices (PMCDs), in accordance with the procedures of 40 CFR 60, Appendix A, 

Method 22. The Method 22 test shall be conducted while the affected source is operating 

at representative performance conditions. The duration of the Method 22 test shall be six

minutes. If visible emissions are observed during any Method 22 visible emissions test,

the Permittee must: 

Initiate, within one (1) hour, the corrective actions specified in the site specific operations and

maintenance plan developed in accordance with 40 CFR §§ 63.1350(a)(1) and (a)(2). 

Within twenty-four (24) hours of the end of the Method 22 test in which visible emissions 

were observed, conduct a follow-up Method 22 test of each stack from which visible

emissions were observed during the previous Method 22 test. If visible emissions are

observed during the follow-up Method 22 test from any stack from which visible emissions were observed during the previous Method 22 test, conduct a visual opacity test of 

each stack from which visible emissions were observed during the follow-up Method 22

test in accordance with 40 CFR Part 60, Appendix A, Method 9. The duration of the

Method 9 test shall be thirty minutes. 

D.3.11 Visible Emissions Notations 

Visible emission notations of all of the baghouse stack exhausts controlling the raw mill storage

facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points 

associated with the clinker handling facilities/emission units (EU25, EU26a, EU26b, EU27, and 

EU29) the roll crusher (EU31), the finish mill facilities/emission units (EU32 through EU36 and 

EU38), and the finish material storage and bulk loading and packaging facilities/emission units 

(EU37, EU39 through EU47) shall be performed once per day during normal daylight operations. 

Visible emission notations of all other baghouse stack exhausts shall be performed once per shift

during normal daylight operations. A trained employee shall record whether emissions are 

normal or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process.
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 66 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) On days that the NESHAP monitoring required in Condition D.3.10 is performed, the

Permittee may use those results to satisfy the requirements of this condition for those

facilities monitored. 

(e) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an abnormal emission is observed. Failure to take

response steps in accordance with Section C - Compliance Response Plan - Preparation, 

Implementation, Records, and Reports, shall be considered a violation of this permit. 

D.3.12 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse associated with

the raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the clinker handling facilities/emission units (EU25, EU26a, 

EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/emission units (EU32

through EU36 and EU38), and the finish material storage and bulk loading and packaging 

facilities/emission units (EU37, EU39 through EU47) at least once per day when the associated 

facility/emission units are in operation and venting to the atmosphere. The Permittee shall record 

the total static pressure drop across all other baghouses at least once per shift when the

associated facility/emission units are in operation and venting to the atmosphere. When for any 

one reading, the pressure drop across a baghouse is outside the normal range of 1.0 and 8.0

inches of water or a range established during the latest stack test, the Permittee shall take

reasonable response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports. A pressure reading that is outside the above

mentioned range is not a deviation from this permit. Failure to take response steps in accordance

with Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.3.13 Baghouse Inspections 

An inspection shall be performed each calendar quarter of all bags controlling the process listed 

in this section when venting to the atmosphere. A baghouse inspection shall be performed within 

three months of redirecting vents to the atmosphere and every three months thereafter. Inspections are optional when venting to the indoors. Inspections required by this condition shall not be 

performed in consecutive months. All defective bags shall be replaced. 

D.3.14 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 67 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(b) For single compartment baghouses, if failure is indicated by a significant drop in the 

baghouse’s pressure readings with abnormal visible emissions or the failure is indicated

by an opacity violation, or if bag failure is determined by other means, such as gas 

temperatures, flow rates, air infiltration, leaks, dust traces, or triboflows, then failed units 

and the associated process will be shut down immediately until the failed units have been

repaired or replaced. Operations may continue only if the event qualifies as an emergency and the Permittee satisfies the requirements of the emergency provisions of this 

permit (Section B - Emergency Provisions). 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.15 Record Keeping Requirements 

(a) To document compliance with Condition D.3.11, the Permittee shall maintain records of

visible emission notations of the baghouse stack exhausts controlling the raw mill storage

facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer 

points associated with the clinker handling facilities/emission units (EU25, EU26a,

EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/emission units

(EU32 through EU36 and EU38), and the finish material storage and bulk loading and

packaging facilities/emission units (EU37, EU39 through EU47) once per day and all 

other baghouse stack exhausts once per shift. 

(b) To document compliance with Condition D.3.12, the Permittee shall maintain records of

the inlet and outlet differential static pressure of each baghouse associated with the raw 

mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the clinker handling facilities/emission units (EU25,

EU26a, EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/ 

emission units (EU32 through EU36 and EU38), and the finish material storage and bulk 

loading and packaging facilities/emission units (EU37, EU39 through EU47) once per day

and all other baghouses once per shift. 

(c) To document compliance with Condition D.3.13, the Permittee shall maintain records of

the results of the inspections required under Condition D.3.13. 

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

maintain all records required by 40 CFR 63.1355. These records include the following: 

(1) The Permittee shall maintain files of all information (including all reports and

notifications) required by 40 CFR 63.1355(a), recorded in a form suitable and

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(e) To document compliance with Condition D.3.6(b)(5), (15), (22) and (25), the Permittee

shall maintain records of the Finish Mill Surge Bin (EU37), the Lime Bin (EU38), the 

Railroad Loadout Bin (EU45), the Articuloader (EU46) and the Packing Machine (EU47)

operating hours. 

(f) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 68 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.3.16 Reporting Requirements 

(a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

report the information required by 40 CFR 63.1354, including, but not limited to the 

following: 

(1) The plan required by Condition D.3.10 shall be submitted to IDEM, OAQ and 

U.S. EPA by June 14, 2002, which is the compliance date for the National

Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland 

Cement Manufacturing Industry. 

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of 

performance tests as part of the notification of compliance status, required in

Section C - NESHAP Notification and Reporting Requirements. 

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results

from tests required by 40 CFR 63.1349. 

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a

startup, shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified in the 

source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), 

the Permittee shall state such information in a semiannual report. Reports shall 

only be required if a startup, shutdown, or malfunction occurred during the 

reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring

system performance reports. 

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee

during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, and 

malfunction plan, the Permittee shall report the actions taken for that event within

2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) 

transmission at (317) 233-6865. The immediate report shall be followed by a 

letter within 7 working days after the end of the event, certified by the Permittee,

explaining the circumstances of the event, the reasons for not following the 

startup, shutdown, and malfunction plan, and whether any excess emissions 

and/or parameter monitoring exceedances are believed to have occurred. 

(b) In addition to being submitted to the address listed in Section C - General Reporting

Requirements, all reports and the operations and maintenance plan submitted pursuant 

to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following 

address: 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Pursuant to 40 CFR 63.10(d), the reports submitted by the Permittee shall include the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(c) A quarterly summary of the information to document compliance with Condition D.3.6 (b) 

shall be submitted to the address listed in Section C - General Reporting Requirements, 

using the reporting forms located at the end of this permit, or the equivalent, within thirty 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 69 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(30) days after the end of the quarter being reported. The reports submitted by the 

Permittee do require the certification by the “responsible official” as defined by 326 IAC 2-

7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 70 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.4 FACILITY/EMISSION UNIT OPERATION CONDITIONS

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

(1) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP1, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #1 is also permitted to use a blended fuel of coal and pressed paper making waste

where the blend has a maximum of 20% pressed paper making waste by heat input. 

Kiln #1 is permitted to use a blended fuel of coal and clean and/or treated wood where the 

blend has a maximum of up to 35% clean and/or treated wood by heat input. 

(2) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP2, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #2 is also permitted to use a blended fuel of coal and pressed paper making waste

where the blend has a maximum of 20% pressed paper making waste by heat input. 

 

Kiln #2 is permitted to use a blended fuel of coal and clean and/or treated wood where the

blend has a maximum of up to 35% clean and/or treated wood by heat input. 

(3) One (1) kiln #3, identified as EU17, constructed in 1974 as a one-stage preheater kiln, with a 

heat input rate of 118 million Btu per hour, with a nominal production rate of 43 tons per hour, 

with PM emissions controlled by one (1) electrostatic precipitator (ESP), identified as KP3, and 

exhausting to one (1) stack, identified as S-KP2. Kiln #3 is also permitted to use a blended 

fuel of coal and pressed paper making waste where the blend has a maximum of 20% pressed

paper making waste by heat input. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.4.1 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

Pursuant to Significant Permit Modification 093-16851-00002 issued in 2003, in order to render

the requirement of 326 IAC 2-2 (PSD) not applicable to the preheater modification, the following 

conditions shall apply upon startup of either preheater Kilns #1 or #2: 

(a) The Clinker production from Kiln #1 (EU15) and Kiln #2 (EU16) shall be limited to 

321,875 tons each per 12 consecutive month period with compliance determined at the 

end of each month. 

(b) PM emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 0.28 lb/ton

clinker. 

(c) PM10 emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 0.59

lb/ton clinker.

 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 71 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(d) NOx emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 11.14

lb/ton clinker.

(e) CO emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 1.67 lb/ton

clinker. 

(f) SO2 emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 7.51 lb/ton

clinker. 

(g) VOC emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 0.30 lb/ton

clinker. 

(h) Lead emissions from each Kiln #1 (EU15) and Kiln #2 (EU16) shall not exceed 1.69E-03

lb/ton clinker.

(i) Sulfuric Acid mist emissions from each Kiln #1 (EU15) and Kiln #2(EU16) shall not 

exceed 3.9E-02 lb/ton clinker. 

(j) H2S emissions from each Kiln #1 (EU15) and Kiln #2(EU16) shall not exceed 0.037

lb/ton clinker.

Therefore, the requirements of 326 IAC 2-2 (PSD) are not applicable to the preheater 

modification. 

D.4.1.1 Kiln #1 and Kiln #2 Partial Fuel Switch [326 IAC 2-2-2(d)(3)] 

Pursuant to 326 IAC 2-2-2(d)(3), Kiln #1 and Kiln #2 are permitted to burn a blended fuel 

of coal and clean and/or treated wood where the blend has a maximum of up to 35% 

clean and/or treated wood by heat input. 

D.4.2 Sulfur Dioxide (SO2) [326 IAC 7-1.1-1] [326 IAC 7-2-1] 

Pursuant to 326 IAC 7-1.1 (SO2 Emissions Limitations) the SO2 emissions from the combustion of 

coal in each of the kilns shall not exceed six (6.0) pounds per MMBtu heat input each. Pursuant 

to 326 IAC 7-2-1, compliance shall be demonstrated on a monthly average. 326 IAC 7-1.1 and 

326 IAC 7-2-1 are not federally enforceable. 

D.4.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

On and after June 14, 2002, the provisions of 40 CFR Part 63, Subpart A - General Provisions, 

which are incorporated by reference in 326 IAC 20-1, apply to kiln #1 (EU15), kiln #2 (EU16), and

kiln #3 (EU17) except when otherwise specified in 40 CFR Part 63, Subpart LLL. 

D.4.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

Pursuant to 40 CFR 63.1343 (Emissions Standards and Operating Limits), on and after June 14,

2002, which is the compliance date for the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, kiln #1 (EU15), kiln #2

(EU16), and kiln #3 (EU17) shall be limited as follows: 

(a) Particulate matter (PM) emissions shall be limited to 0.30 pound per ton of feed (dry 

basis) to the kiln. 

(b) Visible emissions shall be limited to twenty percent (20%) opacity. 

(c) Dioxin/Furan emissions shall be limited to 8.7 x 10-11 grains per dry standard cubic foot

(TEQ) corrected to seven percent oxygen; or 1.7 x 10-10 grains per dry standard cubic 

foot (TEQ) corrected to seven percent oxygen, when the average of the performance test 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 72 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

run average temperatures at the inlet to the particulate matter control device is 400 

degrees Fahrenheit or less. 

(d) The kiln shall be operated such that the three hour rolling average temperature of the gas 

at the inlet to the kiln’s particulate matter control device does not exceed the average of

the run average temperatures determined during the performance tests required in

Condition D.4.7. 

D.4.5 Compliance Assurance Monitoring (CAM) Plan [40 CFR 64] 

IDEM has determined that a Compliance Assurance Monitoring (CAM) Plan, in accordance with 

the requirements of 40 CFR 64, is required for the one-stage preheater kiln #1 (EU15), and the

one-stage preheater kiln #2 (EU16). Pursuant to 40 CFR 64.2, CAM is required because the

potential to emit SO2 is greater than one hundred (100) tons per year before control and the 

source is subject to the emission limitations contained in conditions D.4.1 and D.4.2. A CAM plan 

was received from the source on December 19, 2002. IDEM has determined that compliance

with the monitoring requirements of 40 CFR 63.8 and 40 CFR 63, Subpart LLL (National

Emission Standards for Hazardous Air Pollutants from the Portland Cement Manufacturing

Industry), satisfy the monitoring requirements of 40 CFR 64. 

D.4.6 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for each of the kilns facilities/emissions units and the control devices KP1, 

KP2, and KP3. If the Operations and Maintenance Plan required by Condition D.4.12 is 

developed in accordance with Section B - Preventive Maintenance Plan, then once the Operations and Maintenance Plan has been developed, it shall satisfy this condition. 

Compliance Determination Requirements

D.4.7 NESHAP Testing Requirements [40 CFR 63, Subpart LLL] 

(a) Within 180 days after June 14, 2002, which is the compliance date for the Portland

Cement Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM, opacity and dioxin/furan limits established in Condition D.4.4 by conducting performance tests in accordance with 40 CFR 63.1349 and Section C - 

Performance Testing. The tests for PM shall be repeated at least once every five 5 years 

and the tests for dioxin/furans shall be repeated at least once every 2.5 years from the 

date of this valid compliance demonstration. The Permittee is also required to repeat the

performance tests for particulate matter and dioxins/furans within 90 days of initiating any

significant change in the feed or fuel from that used in the previous test that may 

adversely affect compliance with the applicable particulate matter or dioxins/furans limits. 

These tests shall be conducted in accordance with Section C - Performance Testing.

Pursuant to 40 CFR 63.7(e), the tests shall be conducted under representative operating 

conditions. 

(b) Pursuant to 40 CFR 63.1349, the Permittee is required to repeat the performance tests 

for particulate matter and dioxins/furans within 90 days of startup of preheater Kilns #1

and #2. 

D.4.8 Testing requirement [326 IAC 2-1.1-11]

To verify compliance with condition D.4.1, the permittee shall, within 60 days after achieving

maximum capacity but no later than 180 days after startup of preheater Kilns #1 and #2, perform

PM, PM10, NOx, CO, SO2, VOC, Sulfuric Acid mist, H2S and Lead testing on Kiln #1 (EU15) and

Kiln #2 (EU16). The PM, PM10, NOx, CO, SO2, VOC, Sulfuric Acid mist, H2S, and Lead testing 

for Kilns #1 and #2 shall be repeated every 2.5 years from the Permittee’s initial compliance 

demonstration for each of these pollutants following start-up of the preheater Kilns #1 and #2.
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 73 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.4.9 Particulate Control 

Except as otherwise provided by statute, rule or this permit, the ESPs (KP1, KP2, and KP3) for 

PM control shall be in operation at all times when the associated kiln is in operation, in order to 

demonstrate compliance with Conditions D.4.1 and D.4.4. 

D.4.10 Sulfur Dioxide Emissions from Coal Combustion and Coal Sulfur Content [326 IAC 2-7-5(A)] [326 

IAC 2-7-6] [326 IAC 7-1.1] [326 IAC 7-2]

Pursuant to 326 IAC 7-1.1-2, the Permittee shall demonstrate that the sulfur dioxide emissions 

from coal combustion do not exceed six (6.0) pounds per MMBtu. Pursuant to 326 IAC 7-2,

compliance shall be determined utilizing the following methods: 

(a) Coal sampling and analysis shall be performed using one of the following procedures: 

(1) Minimum Coal Sampling Requirements and Analysis Methods [326 IAC 3-7-

2(b)(3)]: 

(A) The coal sample acquisition point shall be at a location where representative samples of the total coal flow to be combusted by the facility or

facilities may be obtained. A single as-bunkered or as-burned sampling 

station may be used to represent the coal to be combusted by multiple 

facilities using the same stockpile feed system; 

(B) Coal shall be sampled at least three (3) times per day and at least one 

(1) time per eight (8) hour period unless no coal is bunkered during the

preceding eight (8) hour period; 

(C) Minimum sample size shall be five hundred (500) grams; 

(D) Samples shall be composited and analyzed at the end of each calendar 

month; 

(E) Preparation of the coal sample, heat content analysis, and sulfur content 

analysis shall be determined pursuant to 326 IAC 3-7-2(c), (d), (e); 

(2) Sample the coal pursuant to 326 IAC 3-7-2(a). Preparation of the coal sample, 

heat content analysis, and sulfur content analysis shall be determined pursuant 

to 326 IAC 3-7-2(c), (d) and (e); 

(3) Sample and analyze the coal pursuant to 326 IAC 3-7-3. 

(b) Compliance may be determined by conducting a stack test for sulfur dioxide emissions 

from the kilns in accordance with 326 IAC 3-6, utilizing the procedures in 40 CFR 60,

Appendix A, Method 6, 6A, 6C, or 8. [326 IAC 7-2-1(d)] 

A determination of noncompliance pursuant to either of the methods specified in (a) or (b) above 

shall not be refuted by evidence of compliance pursuant to the other method. 

(c) Upon written notification to IDEM by a facility owner or operator, continuous emission 

monitoring data collected and reported pursuant to 326 IAC 3-5-1 may be used as the

means for determining compliance with the emission limitations in 326 IAC 7. Upon such

notification, the other requirements of 326 IAC 7 shall not apply. [326 IAC 7-2-1(g)] 

326 IAC 3-5, 326 IAC 3-6 and 326 IAC 3-7 are not federally enforceable. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 74 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.4.11 Continuous Emissions Monitoring [326 IAC 3-5] [326 IAC 2-7-6(1),(6)] [40 CFR 63, Subpart LLL] 

Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions), 326 IAC 2-1.1-11 and 40 CFR 

Part 63, a continuous monitoring system shall be installed, calibrated, maintained, and operated 

for measuring the opacity from each of the kilns (EU15, EU16 and EU17), pursuant to 326 IAC 3-

5-2 and 40 CFR 63.8(c). The continuous opacity monitor shall meet the performance 

specifications of 326 IAC 3-5-2 and 40 CFR 63.8(c). 326 IAC 3-5 is not federally enforceable. 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.4.12 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] [40 CFR 64.2] 

Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, which is the 

compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) for 

the Portland Cement Manufacturing Industry, the Permittee shall perform the following monitoring

requirements:

(a) The Permittee shall have prepared a written operations and maintenance plan for kiln #1

(EU15), kiln #2 (EU16), and kiln #3 (EU17). The plan shall include the following

information: 

(1) Procedures for proper operation and maintenance of kiln #1 (EU15), kiln #2 

(EU16), and kiln #3 (EU17) and associated air pollution control device(s) in order 

to meet the emissions limit in Condition D.4.4; and 

(2) Procedures to be used during an inspection of the components of the combustion

system of kiln #1 (EU15), kiln #2 (EU16), and kiln #3 (EU17) at least once per

year. 

Failure to comply with any provision of the operations and maintenance plan shall be a

violation of the standard. The contents of the operations and maintenance plan are not

included in this permit and may be modified by the Permittee without modification or

amendment of this permit. 

(b) The Permittee shall conduct an inspection of the components of the combustion system

of kiln #1 (EU15), kiln #2 (EU16), and kiln #3 (EU17) at least once per year. 

(c) The Permittee shall continuously monitor opacity of emissions at the outlet of the PM 

control device. The COM required by Condition D.4.11 shall be used to monitor opacity 

emissions in accordance with the NESHAP 40 CFR 63, Subpart LLL and shall be installed, maintained, calibrated and operated as required by 40 CFR 63, Subpart A. 

(d) The Permittee shall install, calibrate, maintain, and continuously operate a continuous 

monitor to record the temperature of the exhaust gases from kiln #1 (EU15), kiln #2 

(EU16), and kiln #3 (EU17) at the inlet to, or upstream of the kiln’s PM control device. 

(1) The recorder response range must include zero and 1.5 times either of the 

average temperatures established according to the requirements in 40 CFR 

63.1349(b)(3)(iv). 

(2) The reference method must be a National Institute of Standards and Technology

calibrated reference thermocouple-potentiometer system or alternate reference,

subject to approval by the IDEM. 

(3) The three-hour rolling average temperature shall be calculated as the average of

180 successive one-minute average temperatures. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 75 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(4) Periods of time when one-minute averages are not available shall be ignored

when calculating three-hour rolling averages. When one-minute averages

become available, the first one-minute average is added to the previous 179 

values to calculate the three-hour rolling average. 

(5) The calibration of all thermocouples and other temperature sensors shall be 

verified at least once every three months. 

Recording the temperature of the exhaust gases from kiln #1 (EU15) and kiln #2 (EU16) shall 

satisfy the requirement of the Compliance Assurance Monitoring (CAM) Plan for SO2 emissions 

monitoring, in accordance with the requirements of 40 CFR 64. 

D.4.13 Preventive Inspections 

In order to document compliance with the applicable PM and dioxin/furan limits specified in

Condition D.4.1 and Condition D.4.4 the following inspections shall be performed for each ESP: 

(1) Electrostatic precipitator, transformer-rectifier set (“T-R set”) component inspections shall 

be performed during each annual shutdown, but no less often than once every fourteen

(14) months, and during any outage lasting more than five (5) days, unless such inspections have been performed within the last six (6) months. The inspections shall include

the following: 

(A) Internal inspections of shell for corrosion (including but not limited to doors,

hatches, insulator housings, and roof area). 

(B) Effectiveness of rapping (including but not limited to a visual check of dust 

buildup on discharge electrodes and plates). 

(C) Gas distribution (including but not limited to a visual check of dust buildup on

distribution plates and turning vanes). 

(D) Dust accumulation (including but not limited to a visual check of dust buildup on 

shell and support members that could result in grounds or promote advanced 

corrosion).

(E) Major misalignment of plates and electrodes (including but not limited to a visual

check of plate and electrode alignment). 

(F) Rapper, electric hammer, and T-R set control cabinets (including but not limited 

to motors and lubrication). 

(G) Rapper assembly (including but not limited to loose bolts, ground wires, water 

and air lines, and solenoids). 

(H) Electric hammer and rapper boots (including but not limited to air in-leakage, 

wear and deterioration). 

(I) T-R set controllers (including but not limited to voltage and current setpoints). 

(2) Air and water infiltration, once per month. This inspection may consist of audible checks 

around hoppers/hatches, duct expansion joints, and areas of corrosion. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 76 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.4.14 Parametric Monitoring

(a) The ability of the ESPs to control particulate emissions shall be monitored once per day

when the units are in operation, by measuring and recording and comparing the total 

power of the ESP to the minimum total power of thirty-five kilowatts (35 kW). 

(b) When for any reading, the total power is below the minimum total power of 35 kW, the

Permittee shall take reasonable response steps in accordance with Section C – Compliance Response Plan – Preparation, Implementation, Records, and Reports. A total 

power reading below the minimum is not a deviation from this permit. 

Failure to take response steps in accordance with Section C - Compliance Response

Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this permit. 

D.4.15 Opacity Readings 

The ability of the ESP to control particulate emissions shall be monitored by continuously 

measuring and recording the opacity of emissions from each of the kiln stack exhausts (S-KP1

and S-KP2). 

(a) Appropriate response steps shall be taken in accordance with Section C - Compliance 

Response Plan - Preparation, Implementation, Records, and Reports whenever the 

opacity exceeds 18 percent for three (3) consecutive six (6) minute averaging periods. 

Failure to take response steps in accordance with Section C - Compliance Response

Plan - Preparation, Implementation, Records, and Reports, shall be considered a

violation of this permit. 

(b) The opacity shall be determined by the certified continuous opacity monitor required in

Condition D.4.11. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.4.16 Record Keeping Requirements 

(a) In order to document compliance with Conditions D.4.2 and D.4.10, the Permittee shall 

maintain records in accordance with (1) through (4) below. Records maintained for (1) 

through (4) shall be taken monthly and shall be complete and sufficient to establish 

compliance with the SO2 emission limits established in D.4.2. 

(1) Calendar dates covered in the compliance determination period; 

(2) Actual monthly coal usage since last compliance determination period; 

(3) Calendar month average sulfur content and heat content of coal; 

(4) Calendar month average sulfur dioxide emission rates in pounds per million Btu

of heat input. 

326 IAC 7-1.1, 7-2-1, and 326 IAC 3-4, 3-5, 3-6, and 3-7 are not federally enforceable. 

(b) Pursuant to 326 IAC 3-7-5(a), the Permittee shall develop a standard operating procedure (SOP) to be followed for sampling, handling, analysis, quality control, quality assurance, and data reporting of the information collected pursuant to 326 IAC 3-7-2 through

326 IAC 3-7-4. In addition, any revision to the SOP shall be submitted to IDEM, OAQ. 

(c) To document compliance with Conditions D.4.4, D.4.7, D.4.8, D.4.11, D.4.13, D.4.14, and 

D.4.15, the Permittee shall maintain records in accordance with (1) through (6) below.

Records shall be complete and sufficient to establish compliance with the limits estab-
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 77 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

lished in Section C - Opacity and Conditions D.4.4, D.4.7, D.4.8, D.4.11, D.4.13, D.4.14, 

and D.4.15. 

(1) Data and results from the most recent stack test.

(2) All continuous emissions monitoring data. 

(3) All ESP total power readings. 

(4) The results of all ESP inspections and the type and number of parts replaced. 

(5) All preventive maintenance measures taken. 

(6) All response steps taken and the outcome for each. 

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

maintain all records required by 40 CFR 63.1355. These records include the following: 

(1) The Permittee shall maintain files of all information (including all reports and notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and readily 

available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(3) The Permittee shall maintain all records of continuous monitoring system data 

required by 40 CFR 63.10(c). 

(4) The Permittee shall keep records of the results of the inspections of the 

components of the combustion systems of kilns #1, #2, and #3, required by 40

CFR 63.1350 and Condition D.4.12(b), at least once per year. 

(e) To document compliance with the CAM record keeping requirements in 40 CFR 64.9, the 

permittee shall maintain the following records for Preheater Kilns #1 and #2, on site: 

(1) Monitoring data. 

(2) Monitor Performance Data.

(3) Corrective Action Taken. 

(f) To document compliance with Condition D.4.1(a), the Permittee shall maintain records of

the Clinker production from Kiln #1 (EU15) and Kiln #2 (EU16). 

(g) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.4.17 Reporting Requirements 

(a) A quarterly summary of the information to document compliance with the SO2 limit

specified in Condition D.4.2 shall be submitted to the address listed in Section C - 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 78 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

General Reporting Requirements, of this permit, using the reporting form located at the 

end of this permit, or its equivalent, within thirty (30) days after the end of the quarter 

being reported. This report submitted by the Permittee does require the certification by 

the “responsible official” as defined by 326 IAC 2-7-1(34). 

(b) Beginning June 14, 2002, the Permittee shall submit a continuous monitoring system 

(CMS) performance report with the excess opacity summaries, in accordance with 40

CFR 63, Subpart A. 

(c) Beginning June 14, 2002, the Permittee shall submit a semi-annual summary report

which contains the information specified in 40 CFR 63.10(e)(3)(vi), as well as the 

following: 

(1) All exceedances of maximum control device inlet gas temperature limits specified 

in Condition D.4.4. 

(2) All failures to verify the calibration of the thermocouples and other temperature 

sensors as required under 40 CFR 63.1350(f)(6). 

(3) The results of any combustion system component inspections conducted within

the reporting period as required by Condition D.4.12(b). 

(4) All failures to comply with any provision of the operation and maintenance plan

developed in accordance with 40 CFR 63.1350(a). 

If the total continuous monitoring system (CMS) downtime for any CEM or any CMS for 

the reporting period is ten percent or greater of the total operating time for the reporting

period, the Permittee shall submit an excess emissions and CMS performance report 

along with the summary report. 

(d) To document compliance with the NESHAP, the Permittee shall report the information 

required by 40 CFR 63.1354, including, but not limited to the following: 

(1) The plan required by Condition D.4.12 shall be submitted to IDEM, OAQ and 

U.S. EPA by June 14, 2002, which is the compliance date for the National

Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland 

Cement Manufacturing Industry. 

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of 

performance tests as part of the notification of compliance status, required in

Section C - NESHAP Notification and Reporting Requirements. 

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results

from tests required by 40 CFR 63.1349. 

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a

startup, shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified in the 

source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), 

the Permittee shall state such information in a semiannual report. Reports shall 

only be required if a startup, shutdown, or malfunction occurred during the 

reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring

system performance reports. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 79 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee

during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, and 

malfunction plan, the Permittee shall report the actions taken for that event within

2 working days after commencing actions inconsistent with the plan, by telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile (FAX) 

transmission at (317) 233-6865. The immediate report shall be followed by a 

letter within 7 working days after the end of the event, certified by the Permittee,

explaining the circumstances of the event, the reasons for not following the 

startup, shutdown, and malfunction plan, and whether any excess emissions 

and/or parameter monitoring exceedances are believed to have occurred. 

(e) In addition to being submitted to the address listed in Section C - General Reporting

Requirements, all reports and the operations and maintenance plan submitted pursuant 

to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following 

address: 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Pursuant to 40 CFR 63.10(d), the reports submitted by the Permittee shall include the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

(f) To document compliance with the reporting requirements in 40 CFR 64.9(a)(2), the 

permittee shall report the information required by this rule, including but not limited to: 

(1) Summary information on the number, duration and cause (including unknown 

cause, if applicable) of excursions and exceedances, as applicable, and the

corrective actions taken. 

(2) Summary information on the number, duration and cause including unknown 

cause, if applicable) for monitor downtime incidents (other than downtime

associated with zero and span or other daily calibration checks, if applicable)

(g) A quarterly summary of the information to document compliance with Condition D.4.1(a)

shall be submitted to the address listed in Section C - General Reporting Requirements, 

using the reporting forms located at the end of this permit, or the equivalent, within thirty 

(30) days after the end of the quarter being reported. The report submitted by the

Permittee does require the certification by the “responsible official” as defined by 326 IAC 

2-7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 80 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.5 FACILITY/EMISSION UNIT OPERATION CONDITIONS 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The clinker cooler facilities/emissions units, as follows: 

(1) One (1) clinker cooler #1, identified as EU19, constructed in 1959, with a nominal rate of 38 

tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC2, and

exhausting to one (1) stack, identified as S-KDC2. 

(2) One (1) clinker cooler #2, identified as EU21, constructed in 1959, with a nominal rate of 38

tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC4, and 

exhausting to one (1) stack, identified as S-KDC4. 

(3) One (1) clinker cooler #3, identified as EU23, constructed in 1974, with a nominal rate of 43

tons per hour, with PM emissions controlled by one (1) baghouse, identified as KDC6, and 

exhausting to one (1) stack, identified as S-KDC6. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.5.1 Prevention of Significant Deterioration (PSD) [326 IAC 2-2] 

Pursuant to Significant Permit Modification 093-16851-00002 issued in 2003, in order to render

the requirement of 326 IAC 2-2 (PSD) not applicable to the Kiln preheater modification, upon

startup of the preheater Kilns #1 and #2, PM and PM10 emissions from baghouse KDC2 and 

baghouse KDC4 controlling Clinker Cooler #1 (EU19) and Clinker Cooler #2 (EU20) respectively 

shall each not exceed 11.41 pounds per hour. Therefore the requirements of 326 IAC 2-2 (PSD) 

are not applicable to the preheater modification. 

D.5.2 Determinations of Nonapplicability [40 CFR 60, Subparts A and F]

The clinker coolers #1 and #2 (EU19 and EU21) are not subject to the requirements of the New 

Source Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of

Performance for Portland Cement Plants) because they were constructed prior to the applicability 

date of August 17, 1971 and have not been modified since the applicability date. 

D.5.3 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

On and after June 14, 2002, the provisions of 40 CFR Part 63, Subpart A - General Provisions, 

which are incorporated by reference in 326 IAC 20-1, apply to the clinker coolers (EU19, EU21 

and EU23) described in this section except when otherwise specified in 40 CFR Part 63, Subpart 

LLL. 

D.5.4 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

Pursuant to 40 CFR 63.1345 (Emissions Standards and Operating Limits), on and after June 14,

2002, which is the compliance date for the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) from the Portland Cement Manufacturing Industry, each clinker cooler

(EU19, EU21 and EU23) shall be limited as follows: 

(a) Particulate matter (PM) emissions shall be limited to 0.10 pound per ton of feed (dry 

basis) to the kiln. 

(b) Visible emissions shall be limited to ten percent (10%) opacity. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 81 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.5.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for these facilities/emissions units and their control devices listed in this 

section. If the Operations and Maintenance Plan required by Condition D.5.10 is developed in

accordance with Section B - Preventive Maintenance Plan, then once the Operations and 

Maintenance Plan has been developed, it shall satisfy this condition.

Compliance Determination Requirements

D.5.6 NESHAP Testing Requirements [40 CFR 63, Subpart LLL] 

Within 180 days after June 14, 2002, which is the compliance date for the Portland Cement

Manufacturing Industry NESHAP, the Permittee shall demonstrate initial compliance with the PM 

and opacity limits established in Condition D.5.4 by conducting performance tests in accordance

with 40 CFR 63.1349 and Section C - Performance Testing. The PM tests shall be repeated at

least once every 5 years from the date of this valid compliance demonstration. 

D.5.7 Cyclical Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] 

The Permittee shall demonstrate compliance with the PM and PM10 limits established in condition 

D.5.1 within 180 days from the startup of preheater Kilns #1 and #2, by conducting performance

tests for PM and PM10 from Clinker Cooler #1 and Clinker Cooler #2, utilizing methods as

approved by the Commissioner. Testing shall be conducted in accordance with Section C - 

Performance Testing. These PM and PM10 tests shall be conducted every 2.5 years. PM10

includes filter-able and condensible PM10. 

D.5.8 Continuous Emissions Monitoring [326 IAC 3-5] [326 IAC 2-1.1-11] [40 CFR 63, Subpart LLL]

(a) Pursuant to 326 IAC 3-5 (Continuous Monitoring of Emissions), 326 IAC 2-1.1-11, and 40

CFR Part 63, a continuous monitoring system shall be installed, calibrated, maintained, 

and operated for measuring opacity from the clinker coolers (EU19, EU21 and EU23). 

326 IAC 3-5 is not federally enforceable.

(b) The continuous monitoring systems shall meet the performance specifications of 326 IAC

3-5-2 and 40 CFR 63.8(c). 326 IAC 3-5 is not federally enforceable.

D.5.9 Particulate Control 

Except as otherwise provided by statute, rule or this permit, each baghouse (KDC2, KDC4 and

KDC6) for PM control shall be in operation at all times when its associated clinker cooler is in 

operation, in order to demonstrate compliance with Condition D.5.1 and D.5.4.

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)] 

D.5.10 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 14, 2002, which is the 

compliance date for the National Emission Standards for Hazardous Air Pollutants (NESHAP) 

from the Portland Cement Manufacturing Industry, the Permittee shall perform the following 

monitoring requirements: 

(a) The Permittee shall have prepared a written operations and maintenance plan for the

clinker coolers (EU19, EU21 and EU23). The plan shall include the procedures for 

proper operation and maintenance of the clinker coolers (EU19, EU21 and EU23) and

associated air pollution control device(s) in order to meet the emissions limit in Condition 

D.5.4. Failure to comply with any provision of the operations and maintenance plan shall 

be a violation of the standard. The contents of the operations and maintenance plan are

not included in this permit and may be modified by the Permittee without modification or

amendment of this permit. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 82 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(b) The Permittee shall continuously monitor opacity of emissions at the outlet of the PM 

control device. The COM required by Condition D.5.8 shall be used to monitor opacity 

emissions in accordance with the NESHAP and shall be installed, maintained, calibrated

and operated as required by 40 CFR 63, Subpart A and according to 40 CFR 60, 

Appendix B, PS-1. 

D.5.11 Parametric Monitoring

The Permittee shall record the total static pressure drop across each clinker cooler baghouse 

(KDC2, KDC4 and KDC6), at least once per day when the associated facility/emissions unit is in 

operation and venting to the atmosphere. When for any one reading, the pressure drop across a

baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range established 

during the latest stack test, the Permittee shall take reasonable response steps in accordance 

with Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports. A pressure reading that is outside the above mentioned range is not a deviation from

this permit. Failure to take response steps in accordance with Section C - Compliance Response 

Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this 

permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.5.12 Baghouse Inspections 

An inspection shall be performed each calendar quarter of all bags controlling the processes

listed in this section when venting to the atmosphere. Inspections required by this condition shall

not be performed in consecutive months. All defective bags shall be replaced. 

D.5.13 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the

Compliance Response Plan shall be initiated. For any failure with corresponding response 

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 

(b) For single compartment baghouses, if failure is indicated by a significant drop in the baghouse’s pressure readings with abnormal visible emissions or the failure is indicated by

an opacity violation, or if bag failure is determined by other means, such as gas temperatures, flow rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the

associated process will be shut down immediately until the failed units have been repaired or replaced. Operations may continue only if the event qualifies as an emergency

and the Permittee satisfies the requirements of the emergency provisions of this permit 

(Section B - Emergency Provisions). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 83 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.5.14 Opacity Readings

The ability of the baghouses to control particulate emissions shall be monitored by continuously

measuring and recording the opacity of emissions from each of the clinker cooler stack exhausts 

(S-KDC2, S-KDC4, and S-KDC6). 

(a) Appropriate response steps shall be taken in accordance with Section C - Compliance 

Response Plan - Preparation, Implementation, Records, and Reports whenever the opacity 

exceeds 8 percent for three (3) consecutive six (6) minute averaging periods. Failure to 

take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this 

permit. 

(b) The opacity shall be determined by the certified continuous opacity monitor required in

Condition D.5.8. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.5.15 Record Keeping Requirements 

(a) To document compliance with Conditions D.5.4, D.5.6, D.5.7, and D.5.8, the Permittee 

shall maintain records in accordance with (1) and (2) below. 

(1) Data and results from the most recent stack test.

(2) All continuous emissions monitoring data. 

(b) To document compliance with Condition D.5.11, the Permittee shall maintain records of

the differential static pressure of each baghouse once per day. 

(c) To document compliance with Condition D.5.12, the Permittee shall maintain records of

the results of the inspections required under Condition D.5.12. 

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

maintain all records required by 40 CFR 63.1355. These records include the following: 

(1) The Permittee shall maintain files of all information (including all reports and 

notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40 

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(3) The Permittee shall maintain all records of continuous monitoring system data 

required by 40 CFR 63.10(c). 

(e) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.5.16 Reporting Requirements 

(a) A quarterly summary of excess opacity emissions, as defined in 326 IAC 3-5-7 and 40

CFR 63.10, from the continuous monitoring system shall be submitted to the address 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 84 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of 

performance tests as part of the notification of compliance status, required in

Section C - NESHAP Notification and Reporting Requirements. 

listed in Section C - General Reporting Requirements, of this permit, within thirty (30)

days after the end of the quarter being reported. If applicable, the excess opacity 

summary shall also be submitted in accordance with 40 CFR 63.1354(8) (beginning June

14, 2002). 

(b) Beginning June 14, 2002, the Permittee shall submit a continuous monitoring system 

(CMS) performance report with the excess opacity summaries, in accordance with 40

CFR 63, Subpart A. 

(c) Beginning June 14, 2002, the Permittee shall submit a semi-annual summary report

which contains the information specified in 40 CFR 63.10(e)(3)(vi), as well as all failures

to comply with any provision of the operation and maintenance plan developed in 

accordance with 40 CFR 63.1350(a). If the total continuous monitoring system (CMS) 

downtime for any CEM or any CMS for the reporting period is ten percent or greater of 

the total operating time for the reporting period, the Permittee shall submit an excess 

emissions and CMS performance report along with the summary report. 

(d) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

report the information required by 40 CFR 63.1354, including, but not limited to the 

following: 

(1) The plan required by Condition D.5.10 shall be submitted to IDEM, OAQ and 

U.S. EPA by June 14, 2002, which is the compliance date for the National

Emission Standards for Hazardous Air Pollutants (NESHAP) from the Portland 

Cement Manufacturing Industry. 

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results

from tests required by 40 CFR 63.1349. 

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a

startup, shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified in the 

source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), 

the Permittee shall state such information in a semiannual report. Reports shall 

only be required if a startup, shutdown, or malfunction occurred during the 

reporting period. The startup, shutdown, and malfunction report may be submitted simultaneously with the excess emissions and continuous monitoring

system performance reports. 

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee

during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, and 

malfunction plan, the Permittee shall report the actions taken for that event within

2 working days after commencing actions inconsistent with the plan, by 

telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile

(FAX) transmission at (317) 233-6865. The immediate report shall be followed

by a letter within 7 working days after the end of the event, certified by the 

Permittee, explaining the circumstances of the event, the reasons for not 

following the startup, shutdown, and malfunction plan, and whether any excess 

emissions and/or parameter monitoring exceedances are believed to have 

occurred. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 85 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(e) In addition to being submitted to the address listed in Section C - General Reporting

Requirements, all reports and the operations and maintenance plan submitted pursuant 

to 40 CFR 63, Subpart A shall also be submitted to the U.S. EPA at the following 

address: 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Pursuant to 40 CFR 63.10(d), the reports submitted by the Permittee shall include the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 86 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.6 FACILITY/EMISSION UNIT OPERATION CONDITIONS

Facility Description [326 IAC 2-7-5(15)] Insignificant Activity

Degreasing operations that do not exceed 145 gallons per 12 months, except if subject to 326 IAC 20-

6 including one parts washer constructed in 1991. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.6.1 Volatile Organic Compounds (VOC)

Pursuant to 326 IAC 8-3-2 (Cold Cleaner Operations), for cold cleaning operations constructed

after January 1, 1980, the Permittee shall: 

(a) Equip the cleaner with a cover; 

(b) Equip the cleaner with a facility for draining cleaned parts; 

(c) Close the degreaser cover whenever parts are not being handled in the cleaner; 

(d) Drain cleaned parts for at least fifteen (15) seconds or until dripping ceases; 

(e) Provide a permanent, conspicuous label summarizing the operation requirements;

(f) Store waste solvent only in covered containers and not dispose of waste solvent or 

transfer it to another party, in such a manner that greater than twenty percent (20%) of 

the waste solvent (by weight) can evaporate into the atmosphere. 

D.6.2 Volatile Organic Compounds (VOC)

(a) Pursuant to 326 IAC 8-3-5(a) (Cold Cleaner Degreaser Operation and Control), for a cold

cleaner degreaser facility, constructed after July 1, 1990, The Permittee shall ensure that 

the following control equipment requirements are met: 

(1) Equip the degreaser with a cover. The cover must be designed so that it can be 

easily operated with one (1) hand if: 

(A) The solvent volatility is greater than two (2) kiloPascals (fifteen (15) 

millimeters of mercury or three-tenths (0.3) pounds per square inch) 

measured at thirty-eight degrees Celsius (38OC) (one hundred degrees 

Fahrenheit (100OF)); 

(B) The solvent is agitated; or 

(C) The solvent is heated. 

(2) Equip the degreaser with a facility for draining cleaned articles. If the solvent 

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at 

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

then the drainage facility must be internal such that articles are enclosed under

the cover while draining. The drainage facility may be external for applications

where an internal type cannot fit into the cleaning system. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 87 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(3) Provide a permanent, conspicuous label which lists the operating requirements 

outlined in subsection (b). 

(4) The solvent spray, if used, must be a solid, fluid stream and shall be applied at a

pressure which does not cause excessive splashing. 

(5) Equip the degreaser with one (1) of the following control devices if the solvent

volatility is greater than four and three-tenths (4.3) kiloPascals (thirty-two (32) 

millimeters of mercury or six-tenths (0.6) pounds per square inch) measured at 

thirty-eight degrees Celsius (38OC) (one hundred degrees Fahrenheit (100OF)),

or if the solvent is heated to a temperature greater than forty-eight and ninetenths degrees Celsius (48.9OC) (one hundred twenty degrees Fahrenheit 

(120OF)): 

(A) A freeboard that attains a freeboard ratio of seventy-five hundredths

(0.75) or greater. 

(B) A water cover when solvent is used is insoluble in, and heavier than, 

water. 

(C) Other systems of demonstrated equivalent control such as a refrigerated

chiller of carbon adsorption. Such systems shall be submitted to the

U.S. EPA as a SIP revision. 

(b) Pursuant to 326 IAC 8-3-5(b) (Cold Cleaner Degreaser Operation and Control), the 

owner or operator of a cold cleaning facility, construction of which commenced after July 

1, 1990, shall ensure that the following operating requirements are met: 

(1) Close the cover whenever articles are not being handled in the degreaser. 

(2) Drain cleaned articles for at least fifteen (15) seconds or until dripping ceases. 

(3) Store waste solvent only in covered containers and prohibit the disposal or

transfer of waste solvent in any manner in which greater than twenty percent 

(20%) of the waste solvent by weight could evaporate. 

D.6.3 Determination of Nonapplicability [40 CFR 63.460 (Subpart T)] [40 CFR 60, Subparts A and F]

[40 CFR 63, Subparts A and LLL] 

(a) None of the parts washers specifically listed in this section are subject to the requirements of the National Emissions Standards for Hazardous Air Pollutants (NESHAP) 326

IAC 20-1, 40 CFR 63.460 (Subpart T) because they do not utilize a solvent containing 

methylene chloride, perchloroethylene, trichloroethylene, 1,1,1-trichloroethane, carbon

tetrachloride, or chloroform, or any combination of these halogens, in a total concentration greater than five percent by weight. 

(b) The parts washers at this source are not subject to the requirements of the New Source

Performance Standards (NSPS), 40 CFR 60, Subparts A and F (Standards of Performance for Portland Cement Plants) because they are not considered affected facilities 

under this rule. 

(c) The parts washers at this source are not subject to the requirements of the National 

Emissions Standards for Hazardous Air Pollutants (NESHAP) 40 CFR 63 Subparts A and

LLL, because they are not considered affected facilities under this rule. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 88 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

SECTION D.7 FACILITY/EMISSION UNIT OPERATION CONDITIONS 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

Calcium sulfate material facilities/emission units, consisting of the following: 

(iii) Two (2) storage piles, identified as F10 and F12, with emissions uncontrolled and exhausting to 

the atmosphere, potential capacity: 0.10 and 0.05 acres, respectively. 

(jjj) One (1) synthetic gypsum hopper, identified as F11, with emissions uncontrolled and

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(kkk) One (1) synthetic gypsum weight belt, identified as F15, with emissions uncontrolled and

exhausting to the atmosphere, maximum throughput: 60 tons per hour. 

(lll) One (1) raw material hopper, identified as F13, with emissions uncontrolled and exhausting to 

the atmosphere, maximum throughput: 60 tons per hour. 

(mmm) One (1) raw material weight belt, identified as F16, with emissions uncontrolled and exhausting

to the atmosphere, maximum throughput: 60 tons per hour. 

(nnn) One (1) main belt #1, identified as F17, with emissions uncontrolled and exhausting to the

atmosphere, maximum throughput: 100 tons per hour. 

(ooo) One (1) enclosed CKD conveyor #1, identified as EU50, maximum throughput: 50 tons per 

hour. 

(ppp) One (1) CKD storage silo, identified as EU48, previously used as a blending bin, with

particulate emissions controlled by an existing baghouse, identified as RMDC5, and exhausting

to stack S-RMDC5, maximum throughput: 50 tons per hour. 

(qqq) One (1) enclosed CKD conveyor #2, identified as EU51, maximum throughput: 50 tons per 

hour. 

(rrr) One (1) enclosed pugmill, identified as EU49, maximum capacity: 100 tons per hour. 

(sss) One (1) main belt #2, identified as F18, with emissions uncontrolled and exhausting to the

atmosphere, maximum throughput: 100 tons per hour. 

(ttt) One (1) outdoor, partially enclosed calcium sulfate material storage pile, identified as F14, 

potential capacity: 0.10 acre. 

(The information describing the processes contained in this facility description box is descriptive

information and does not constitute enforceable conditions.)

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.7.1 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by 

reference in 326 IAC 20-1, apply to the following calcium sulfate material facilities/emission units 

except when otherwise specified in 40 CFR Part 63, Subpart LLL: one (1) synthetic gypsum

hopper (F11), one (1) raw material hopper (F13), and one (1) enclosed pugmill (EU49); and the

conveyor transfer points associated with the one (1) synthetic gypsum weight belt (F15), one (1) 

raw material weight belt (F16), one (1) main belt #1 (F17), and one (1) main belt #2 (F18). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 89 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

D.7.2 NESHAP Emissions Limitation [326 IAC 20-27] [40 CFR 63.1348] 

Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), the visible emissions 

from the following calcium sulfate material facilities/emission units shall each not exceed ten 

percent (10%) opacity: one (1) synthetic gypsum hopper (F11), one (1) raw material hopper 

(F13), and one (1) enclosed pugmill (EU49); and the conveyor transfer points associated with the 

one (1) synthetic gypsum weight belt (F15), one (1) raw material weight belt (F16), one (1) main 

belt #1 (F17), and one (1) main belt #2 (F18). 

D.7.3 Particulate [326 IAC 6-3-2]

Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes), the

allowable particulate emission rate from the calcium sulfate material facilities/emission units shall

not exceed 51.3 pounds per hour, total, when operating at a process weight rate of 100 tons per 

hour. 

The pounds per hour limitation was calculated with the following equation: 

Interpolation and extrapolation of the data for the process weight rate in excess of 60,000 pounds 

per hour shall be accomplished by use of the equation:

E = 55.0 P0.11 - 40 where E = rate of emission in pounds per hour; and 

P = process weight rate in tons per hour 

D.7.4 PSD Minor Limit [326 IAC 2-2] 

Pursuant to Significant Permit Modification 093-18649-00002, issued in 2004, the following

conditions shall apply upon issuance: 

(a) The material input to the synthetic gypsum and raw materials storage piles (F10 and F12)

shall not exceed 50,000 tons per twelve (12) consecutive month period, total, with

compliance determined at the end of each month. The PM emissions shall not exceed 

0.0121 pounds per ton of material input, and the PM10 emissions shall not exceed 0.0057 

pounds per ton of material input. 

(b) The material input to the synthetic gypsum hopper (F11) shall not exceed 35,000 tons per 

twelve (12) consecutive month period, with compliance determined at the end of each

month. The PM emissions shall not exceed 0.0121 pounds per ton of material input, and

the PM10 emissions shall not exceed 0.0057 pounds per ton of material input. 

(c) The material input to the synthetic gypsum weight belt (F15) shall not exceed 35,000 tons

per twelve (12) consecutive month period, with compliance determined at the end of each

month. The PM emissions shall not exceed 0.0121 pounds per ton of material input, and

the PM10 emissions shall not exceed 0.0057 pounds per ton of material input. 

(d) The material input to the raw material hopper (F13) shall not exceed 15,000 tons per 

twelve (12) consecutive month period, with compliance determined at the end of each

month. The PM emissions shall not exceed 0.0121 pounds per ton of material input, and

the PM10 emissions shall not exceed 0.0057 pounds per ton of material input. 

(e) The material input to the raw material weight belt (F16) shall not exceed 15,000 tons per 

twelve (12) consecutive month period, with compliance determined at the end of each

month. The PM emissions shall not exceed 0.0121 pounds per ton of material input, and

the PM10 emissions shall not exceed 0.0057 pounds per ton of material input. 

(f) The material input to the Main Belt #1 (F17) shall not exceed 50,000 tons per twelve (12) 

consecutive month period, with compliance determined at the end of each month. The
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 90 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

PM emissions shall not exceed 0.0121 pounds per ton of material input, and the PM10

emissions shall not exceed 0.0057 pounds per ton of material input. 

(g) The material input to the CKD silo (EU48) shall not exceed 35,000 tons per twelve (12) 

consecutive month period, with compliance determined at the end of each month. The

PM emissions shall not exceed 0.0121 pounds per ton of material input, and the PM10

emissions shall not exceed 0.0057 pounds per ton of material input. 

(h) The material input to the pugmill (EU49) shall not exceed 85,000 tons per twelve (12) 

consecutive month period, with compliance determined at the end of each month. The

PM emissions shall not exceed 0.0121 pounds per ton of material input, and the PM10

emissions shall not exceed 0.0057 pounds per ton of material input. 

(i) The material input to the Main Belt #2 (F18) shall not exceed 85,000 tons per twelve (12) 

consecutive month period, with compliance determined at the end of each month. The

PM emissions shall not exceed 0.0121 pounds per ton of material input, and the PM10

emissions shall not exceed 0.0057 pounds per ton of material input. 

(j) The material input to the outdoor calcium sulfate material storage pile (F14) shall not 

exceed 85,000 tons per twelve (12) consecutive month period, with compliance 

determined at the end of each month. The PM emissions shall not exceed 0.0121

pounds per ton of material input, and the PM10 emissions shall not exceed 0.0057 pounds 

per ton of material input. 

These limits will ensure that the PM and PM10 emissions increase from the modifications 

permitted in Significant Permit Modification 093-16851-00002 issued on July 11, 2003, and

Significant Permit Modification 093-18649-00002 issued in 2004 will not exceed 25 and 15 tons 

per year, respectively. Therefore, the requirements of 326 IAC 2-2 (PSD) are not applicable to

these modifications. 

D.7.5 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for these facilities/emissions units and their control devices listed in this 

section.

Compliance Determination Requirements

D.7.6 NESHAP Testing Requirements [326 IAC 20-27] [40 CFR 63.1349] 

Within 180 days after startup of the one (1) synthetic gypsum hopper (F11), one (1) raw material

hopper (F13), and one (1) enclosed pugmill (EU49); and the conveyor transfer points associated 

with the one (1) synthetic gypsum weight belt (F15), one (1) raw material weight belt (F16), one

(1) main belt #1 (F17), and one (1) main belt #2 (F18), the Permittee shall demonstrate initial 

compliance with the opacity limits established in Condition D.7.2 by conducting performance tests 

in accordance with 40 CFR 63.1349 and Method 9 of 40 CFR Part 60, Appendix A. 

D.7.7 Particulate Control 

In order to comply with condition D.7.3, the baghouse for particulate control shall be in operation 

and control emissions from the CKD storage silo, identified as EU48, at all times that the CKD 

storage silo is in operation. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 91 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Compliance Monitoring Requirements [326 IAC 2-7-6(1)] [326 IAC 2-7-5(1)]

D.7.8 Compliance Monitoring [326 IAC 2-7-5(3)] [326 IAC 2-7-6(1)] 

All monitoring and record keeping requirements in this section shall be implemented when

operation begins. The Permittee shall be responsible for installing any necessary equipment and 

initiating any required monitoring related to that equipment. 

D.7.9 NESHAP Monitoring Requirements [326 IAC 20-27] [40 CFR 63.1350] 

Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a written 

operations and maintenance plan for the following calcium sulfate material facilities/emission

units: the one (1) synthetic gypsum hopper (F11), one (1) raw material hopper (F13), and one (1) 

enclosed pugmill (EU49); and the conveyor transfer points associated with the one (1) synthetic 

gypsum weight belt (F15), one (1) raw material weight belt (F16), one (1) main belt #1 (F17), and

one (1) main belt #2 (F18), upon startup. The plan shall include the following information: 

(a) Procedures for proper operation and maintenance of the affected sources in order to 

meet the emissions limit in the rule; and

(b) Procedures to be used to periodically monitor the facilities listed in this section, which are 

subject to opacity standards under 40 CFR 63.1348. Such procedures must include the

following provisions: 

(1) The Permittee shall conduct a monthly 1-minute visible emissions test of each 

affected source, in accordance with 40 CFR 60, Appendix A, Method 22. The test

must be conducted while the affected source is in operation. 

(2) If no visible emissions are observed in six consecutive monthly tests for any 

affected source, the Permittee may decrease the frequency of testing from

monthly to semi-annually for that affected source. If visible emissions are

observed during any semi-annual test, the Permittee shall resume testing of that 

affected source on a monthly basis and maintain that schedule until no visible 

emissions are observed in six consecutive monthly tests. 

(3) If no visible emissions are observed during the semi-annual test for any affected

source, the Permittee may decrease the frequency of testing from semi-annually 

to annually for that affected source. If visible emissions are observed during any 

annual test, the Permittee shall resume testing of that affected source on a 

monthly basis and maintain that schedule until no visible emissions are observed

in six consecutive monthly tests. 

(4) If visible emissions are observed during any Method 22 test, the Permittee must 

conduct a 6-minute test of opacity in accordance with 40 CFR 60, Appendix A, 

Method 9. The Method 9 test must begin within one hour of any observation of

visible emissions. 

(5) The requirement to conduct Method 22 visible emissions monitoring under this

paragraph shall not apply to any totally enclosed conveying system transfer

point, regardless of the location of the transfer point. “Totally enclosed conveying

system transfer point” shall mean a conveying system transfer point that is 

enclosed on all sides, top, and bottom. The enclosures for these transfer points 

shall be operated and maintained as total enclosures on a continuing basis in 

accordance with the facility operations and maintenance plan. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 92 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(6) If any partially enclosed or unenclosed conveying system transfer point is located

in a building, the Permittee shall have the option to conduct a Method 22 visible

emissions monitoring test according to the requirements of paragraphs (1) 

through (4) of this section for each such conveying system transfer point located

within the building, or for the building itself, according to paragraph (7) below. 

(7) If visible emissions from a building are monitored, the requirements of paragraphs (1) through (4) of this section apply to the monitoring of the building, and

the Permittee shall also test visible emissions from each side, roof and vent of 

the building for at least 1 minute. The test must be conducted under normal 

operating conditions. 

Failure to comply with any provision of the operations and maintenance plan shall be a violation 

of the standard. 

D.7.10 Visible Emissions Notations 

(a) Visible emission notations of the calcium sulfate material facilities/emission units,

including the synthetic gypsum hopper (F11), synthetic gypsum weight belt (F15), raw 

material hopper (F13), raw material weight belt (F16), main belt #1 (F17), CKD storage

silo (EU48), main belt #2 (F18), and all transfer points shall be performed once per shift 

during normal daylight operations. A trained employee shall record whether emissions 

are normal or abnormal. 

(b) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(c) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(d) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process. 

(e) The Compliance Response Plan for this unit shall contain troubleshooting contingency 

and response steps for when an abnormal emission is observed. Failure to take

response steps in accordance with Section C - Compliance Response Plan - Preparation, 

Implementation, Records, and Reports, shall be considered a deviation from this permit.

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.7.11 Record Keeping Requirements [326 IAC 20-27] [40 CFR 63.1355]

(a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

maintain all records required by 40 CFR 63.1355. These records include the following: 

(1) The Permittee shall maintain files of all information (including all reports and

notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and 

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 93 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

(B) All records of applicability determination, including supporting analyses. 

(b) To document compliance with Condition D.7.4, the Permittee shall maintain records of

the material input to each process at the calcium sulfate material facilities/emission units.

Records shall be complete and sufficient to demonstrate compliance with Condition

D.7.4. 

(c) To document compliance with Condition D.7.5, the Permittee shall maintain records of

any additional inspections prescribed by the Preventive Maintenance Plan. 

(d) To document compliance with Condition D.7.10, the Permittee shall maintain records of

visible emission notations of the calcium sulfate material facilities/emission units, 

including the synthetic gypsum hopper (F11), synthetic gypsum weight belt (F15), raw 

material hopper (F13), raw material weight belt (F16), main belt #1 (F17), CKD storage

silo (EU48), main belt #2 (F18), and all transfer points once per shift. 

(e) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.7.12 Reporting Requirements [326 IAC 20-27] [40 CFR 63.1354] 

(a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall

report the information required by 40 CFR 63.1354, including, but not limited to the 

following: 

(1) The plan required by 40 CFR 63.1350 shall be submitted to IDEM, OAQ and U.S. 

EPA upon startup of the one (1) synthetic gypsum hopper (F11), one (1) raw 

material hopper (F13), and one (1) enclosed pugmill (EU49); and the conveyor 

transfer points associated with the one (1) synthetic gypsum weight belt (F15), 

one (1) raw material weight belt (F16), one (1) main belt #1 (F17), and one (1) 

main belt #2 (F18). 

(2) As required by 40 CFR 63.10(d)(2), the Permittee shall report the results of 

performance tests as part of the notification of compliance status, 

(3) As required by 40 CFR 63.10(d)(3), the Permittee shall report the opacity results

from tests required by 40 CFR 63.1349. 

(4) As required by 40 CFR 63.10(d)(5), if actions taken by the Permittee during a

startup, shutdown, or malfunction of an affected source (including actions taken

to correct a malfunction) are consistent with the procedures specified in the 

source’s startup, shutdown, and malfunction plan specified in 40 CFR 63.6(e)(3), 

the Permittee shall state such information in a semiannual report. Reports shall

only be required if a startup, shutdown, or malfunction occurred during the reporting period. The startup, shutdown, and malfunction report may be submitted 

simultaneously with the excess emissions and continuous monitoring system

performance reports. 

(5) Pursuant to 40 CFR 63.10(d)(5)(ii), any time an action taken by the Permittee

during a startup, shutdown, or malfunction (including actions taken to correct a 

malfunction) is not consistent with the procedures in the startup, shutdown, and 

malfunction plan, the Permittee shall report the actions taken for that event within

2 working days after commencing actions inconsistent with the plan, by 

telephone call to the OAQ Compliance Section at (317) 233-5674 or facsimile

(FAX) transmission at (317) 233-6865. The immediate report shall be followed by

a letter within 7 working days after the end of the event, certified by the Permittee,
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 94 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

explaining the circumstances of the event, the reasons for not following the 

startup, shutdown, and malfunction plan, and whether any excess emissions 

and/or parameter monitoring exceedances are believed to have occurred. 

(b) The Permittee shall submit a semi-annual summary report which contains the information

specified in 40 CFR 63.10(e)(3)(vi), as well as all failures to comply with any provision of

the operation and maintenance plan developed in accordance with 40 CFR 63.1350(a). 

(c) In addition to being submitted to the address listed in Section C - General Reporting

Requirements, all reports required by this section and the operations and maintenance 

plan submitted pursuant to 40 CFR 63, Subpart A shall also be submitted to the U.S. 

EPA at the following address:

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

Pursuant to 40 CFR 63.10(d), the reports submitted by the Permittee shall include the 

certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 

D.7.13 Reporting Requirements 

A quarterly summary of the information to document compliance with Condition D.7.4 shall be 

submitted to the address listed in Section C - General Reporting Requirements, of this permit, 

using the reporting forms located at the end of this permit, or their equivalent, within thirty (30)

days after the end of the quarter being reported. The report submitted by the Permittee does 

require the certification by the “responsible official” as defined by 326 IAC 2-7-1(34). 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 95 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT 

CERTIFICATION

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

This certification shall be included when submitting monitoring, testing reports/results 

or other documents as required by this permit.

 Please check what document is being certified: 

 Annual Compliance Certification Letter 

 Test Result (specify) _________________________________________________________

 Report (specify) _____________________________________________________________ 

 Notification (specify) __________________________________________________________ 

 Affidavit (specify) ____________________________________________________________ 

 Other (specify) _______________________________________________________________ 

I certify that, based on information and belief formed after reasonable inquiry, the statements and 

information in the document are true, accurate, and complete. 

Signature: 

Printed Name: 

Title/Position:

Date: 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 96 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

100 North Senate Avenue 

Indianapolis, Indiana 46204-2251 

Phone: 317-233-5674 

Fax: 317-233-5967 

PART 70 OPERATING PERMIT 

EMERGENCY OCCURRENCE REPORT

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

This form consists of 2 pages Page 1 of 2 

 This is an emergency as defined in 326 IAC 2-7-1(12) 

• The Permittee must notify the Office of Air Quality (OAQ), within four (4) business hours

(1-800-451-6027 or 317-233-5674, ask for Compliance Section); and 

• The Permittee must submit notice by mail or facsimile within two (2) working days 

(Facsimile Number: 317-233-5967), and follow the other requirements of 326 IAC 2-7-16. 

If any of the following are not applicable, mark N/A 

Facility/Equipment/Operation: 

Control Equipment: 

Permit Condition or Operation Limitation in Permit: 

Description of the Emergency: 

Describe the cause of the Emergency: 

If any of the following are not applicable, mark N/A Page 2 of 2
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 97 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Date/Time Emergency started: 

Date/Time Emergency was corrected: 

Was the facility being properly operated at the time of the emergency? Y N 

Describe: 

Type of Pollutants Emitted: TSP, PM-10, SO2, VOC, NOX, CO, Pb, other: 

Estimated amount of pollutant(s) emitted during emergency: 

Describe the steps taken to mitigate the problem: 

Describe the corrective actions/response steps taken:

Describe the measures taken to minimize emissions: 

If applicable, describe the reasons why continued operation of the facilities are necessary to prevent 

imminent injury to persons, severe damage to equipment, substantial loss of capital investment, or loss 

of product or raw materials of substantial economic value: 

Form Completed by: _________________________________________

Title / Position: _________________________________________

Date: _________________________________________

Phone: _________________________________________

A certification is not required for this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 98 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report for Use When Combusting Coal

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Kilns #1, 2, and 3 

Parameter: Sulfur Dioxide (SO2) from coal combustion 

Limit: 6.0 pounds per million Btu heat input 

FACILITY: YEAR: 

Month 

Monthly Average 

Coal Sulfur Content 

(%) 

Monthly Average 

Coal Heat Content 

(MMBtu/lb) 

Coal 

Consumption 

(Tons) 

Equivalent Sulfur 

Dioxide Emissions 

(lbs/MMBtu)

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 99 of 125 

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Primary crusher (EU01) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 100 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Surge Bin and Transfer System (EU02)

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 101 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Secondary Crusher (EU03) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 102 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Tertiary Crusher (EU04) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 103 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The North Screen House (EU05)

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 104 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The South Screen House (EU06)

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 105 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Belt 7/8 Conveyor Transfer Point (EU07) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 106 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: The Belt 8/9 Conveyor transfer point (EU08) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 107 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Conveying System to Transport Raw Material to Storage (EU09)

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 108 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Shale Crusher (EU10)

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 109 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Lime Bin (EU38) 

Parameter: Operating Time 

Limit: 2,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

 YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 110 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Finish Mill Surge Bin (EU37) 

Parameter: Operating Time 

Limit: 1,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

 YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 111 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Railroad Loadout Bin (EU45) and Articuloader (EU46) 

Parameter: Operating Time 

Limit: 2,000 hours per 12 consecutive month period with compliance determined at the end 

of each month 

 

YEAR: 

Column 1 Column 1 Column 2 Column 1 + Column 2 

Month 

This Month This Month Previous 11 Months 12 Month Total 

Railroad Loadout Bin 

(EU45) 

Month 1 

Articuloader (EU46)

Railroad Loadout Bin 

(EU45) 

Month 2 

Articuloader (EU46)

Railroad Loadout Bin 

(EU45) 

Month 3 

Articuloader (EU46)

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 112 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Packing Machine (EU47) 

Parameter: Operating Time 

Limit: 5,500 hours per 12 consecutive month period with compliance determined at the end 

of each month 

 YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month 

This Month Previous 11 Months 12 Month Total 

Month 1 

Month 2 

Month 3 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 113 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Kiln #1 (EU15) and Kiln #2 (EU16) 

Parameter: Throughput 

Limit: 321,875 tons each per 12 consecutive month period with compliance determined at 

the end of each month 

 YEAR: 

Column 1 Column 2 Column 1 + Column 2 

Month Facility 

This Month Previous 11 Months 12 Month Total 

Month 1 Kiln #1 

Kiln #2 

Month 2 Kiln #1 

Kiln #2 

Month 3 Kiln #1 

Kiln #2 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 114 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT 

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

PART 70 OPERATING PERMIT 

QUARTERLY DEVIATION AND COMPLIANCE MONITORING REPORT

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Months: ___________ to ____________ Year: ______________

Page 1 of 2

This report shall be submitted quarterly based on a calendar year. Any deviation from the 

requirements, the date(s) of each deviation, the probable cause of the deviation, and the response 

steps taken must be reported. Deviations that are required to be reported by an applicable requirement 

shall be reported according to the schedule stated in the applicable requirement and do not need to be 

included in this report. Additional pages may be attached if necessary. If no deviations occurred, 

please specify in the box marked “No deviations occurred this reporting period”.

 NO DEVIATIONS OCCURRED THIS REPORTING PERIOD.

 THE FOLLOWING DEVIATIONS OCCURRED THIS REPORTING PERIOD

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 115 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

Page 2 of 2

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Permit Requirement (specify permit condition #)

Date of Deviation: Duration of Deviation:

Number of Deviations:

Probable Cause of Deviation:

Response Steps Taken:

Completed by: 

Title / Position: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 116 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facilities: Storage Piles (F10 and F12) 

Parameter: Material input

Limit: 50,000 tons per twelve (12) consecutive month period, total, with compliance 

determined at the end of each month 

YEAR: ______________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 117 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Synthetic Gypsum Hopper (F11) 

Parameter: Material input

Limit: 35,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 118 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Synthetic Gypsum Weight Belt (F15) 

Parameter: Material input

Limit: 35,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 119 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Raw Material Hopper (F13) 

Parameter: Material input

Limit: 15,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 120 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Raw Material Weight Belt (F16) 

Parameter: Material input

Limit: 15,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 121 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Main Belt #1 (F17) 

Parameter: Material input

Limit: 50,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 122 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: CKD Silo (EU48) 

Parameter: Material input

Limit: 35,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 123 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Pugmill (EU49) 

Parameter: Material input

Limit: 85,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 124 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

COMPLIANCE DATA SECTION 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Main Belt #2 (F18) 

Parameter: Material input

Limit: 85,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Lehigh Cement Company Significant Permit Modification No.:093-21975-00002 Page 125 of 125

Mitchell, Indiana Modified By: W. Habeeb OP No. T093-5990-00002 

Permit Reviewer: Nisha Sizemore 

COMPLIANCE DATA SECTION 

INDIANA DEPARTMENT OF ENVIRONMENTAL MANAGEMENT

OFFICE OF AIR QUALITY 

Part 70 Quarterly Report 

Source Name: Lehigh Cement Company 

Source Address: 121 North First Street, Mitchell, Indiana 47446 

Mailing Address: P.O. Box 97, Mitchell, Indiana 47446 

Part 70 Permit No.: T093-5990-00002 

Facility: Outdoor Calcium Sulfate Material Storage Pile (F14) 

Parameter: Material input

Limit: 85,000 tons per twelve (12) consecutive month period with compliance determined

at the end of each month 

YEAR: ___________________ 

Material Input (tons) Material Input (tons) Material Input (tons) Month 

This Month Previous 11 Months 12 Month Total 

 No deviation occurred in this quarter. 

 Deviation/s occurred in this quarter. 

Deviation has been reported on: 

Submitted by: 

Title / Position: 

Signature: 

Date: 

Phone: 

Attach a signed certification to complete this report. 
Indiana Department of Environmental Management

Office of Air Quality

Addendum to a Technical Support Document (TSD) for a Significant Source Modification and a 

Significant Permit Modification for a Part 70 Permit 

Source Background and Description 

Source Name: Lehigh Cement Company 

 Source Location: 121 North First Street, P.O. Box 97, Mitchell, 

Indiana 47446 

 County: Lawrence 

SIC Code: 3241 

 Operation Permit No.: T093-5990-00002 

Operation Permit Issuance Date: December 30, 2002 

Significant Source Modification No.: 093-21793-00002 

Significant Permit Modification No.: 093-21975-00002 

 Permit Reviewer: Walter Habeeb 

On March 1, 2006 the Office of Air Quality (OAQ) had a notice published in The Bedford 

Times-Mail Newspaper in Lawrence County, stating that Lehigh Cement Company had applied 

for a Significant Source Modification and a Significant Permit Modification to modify their existing 

Kiln #1 and Kiln #2. The notice also stated that OAQ proposed to issue a permit for this operation 

and provided information on how the public could review the proposed permit and other 

documentation. Finally, the notice informed interested parties that there was a period of thirty 

(30) days to provide comments on whether this permit should be issued as proposed. 

On March 31, 2006, Lehigh Cement Company submitted comments on the proposed 

Significant Source Modification and Significant Permit Modification. A summary of the comments 

and the IDEM response is as follows (bold language has been added and language with a line 

through it has been deleted): 

Comment 1 

IDEM should only include the affected conditions/pages of Lehigh’s Part 70 

Operating Permit in the Significant Permit Modification No. 093-21975-00002. IDEM 

has issued numerous Significant Permit Modifications utilizing this method of 

attaching the affected conditions/pages without reissuing the entire permit, and has 

even done so in the last thirty (30) days. 

Lehigh appealed its Initial Part 70 Operating Permit, its First Significant Permit 

Modification and its Second Significant Permit Modification to the Indiana Office of 

Environmental Adjudication and Lehigh and IDEM staff have spent numerous hours 

negotiating stay agreements regarding these appeals. Lehigh would like to avoid 

having to appeal its Significant Permit and Source Modifications Nos. 093-21975-

00002 and 093-21793-00002 to clarify the amendments to its existing Part 70 

Operating Permit and the effectiveness of the terms and conditions of its existing stay 

agreements and previously issued permits. 

Moreover, the changes to Lehigh’s Part 70 Operating Permit will be much more 

apparent and less confusing to both Lehigh and the public if the Permit Modification 

attaches only the affected conditions/pages rather than the entire permit. 

In any event, the letter/approval accompanying the Permit Modification should set 

forth and explain the changes to Lehigh's Part 70 Operating Permit as drafted in the 

red-lined copy of the draft approval letter attached as Attachment A1. 
Lehigh Cement Company Page 2 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Response 1 

 

IDEM’s current practice is to issue the entire permit when issuing a significant permit 

modification. Therefore, IDEM will issue the entire permit. However, IDEM has 

agreed to change the Significant Permit Modification Approval Letter as requested. 

Comment 2 

Even though estimated emissions from Lehigh’s proposed treated wood modification 

request indicate that hazardous air pollutant (“HAP”) emissions fall below the ten tons 

per year (10 tpy) threshold for a single HAP and the twenty-five tons per year (25 tpy) 

threshold for any combination of HAPs, Lehigh conservatively requested that its 

Treated Wood Modification Request be processed as a significant modification 

because no U.S. EPA AP-42 emission factors exist for kilns utilizing a blended fuel of 

coal and treated wood, thus Lehigh had to rely on emission factors for kilns burning 

coal. Since the proposed modification does not involve any construction and is 

subject to 326 IAC 2-7-10.5 because the source is otherwise being modified as 

described in the rule, please modify the Significant Source Modification Approval 

letter consistent with the red-lined copy of the draft approval letter attached as 

Attachment B1. References to construction in the approval letter are misleading 

and confusing. 

Lehigh’s Source Modification does not involve construction, thus the requirement to 

commence construction within eighteen (18) months pursuant to 326 IAC 2-1.1-9 and 

326 IAC 2-7-10.5(i) is not applicable to Lehigh’s modification. In fact, in the last 

month, IDEM has issued other Source Modification Approval Letters for modifications 

that do not involve construction without said restriction/condition. Additionally, in 

accordance with 326 IAC 2-7-10.5(g)(4)(C), the last source modification condition 

and the paragraph immediately following same need to be amended for clarity. 

Response 2 

IDEM agrees with the changes proposed in Attachment B1, and the Significant 

Source Modification Approval Letter has been changed as requested. 

Comment 3 

Delete the redundant language included on the cover page of the Draft Permit 

Modification which reads: “The Permittee must comply with all conditions of this 

permit. . .” This language is already contained in Condition B.8 of Lehigh’s existing 

Part 70 Operating Permit. 

Response 3 

IDEM agrees and has modified the cover page of the Significant Permit Modification 

No. 093-21975-00002 as requested: 

The Permittee must comply with all conditions of this permit. Noncompliance with 

any provisions of this permit is grounds for enforcement action; permit termination, 

revocation and reissuance, or modification; or denial of a permit renewal application. 

Noncompliance with any provision of this permit, except any provision specifically 

designated as not federally enforceable, constitutes a violation of the Clean Air Act. 

It shall not be a defense for the Permittee in an enforcement action that it would have 

been necessary to halt or reduce the permitted activity in order to maintain 

compliance with the conditions of this permit. An emergency does constitute an 

affirmative defense in an enforcement action provided the Permittee complies with 

the applicable requirements set forth in Section B, Emergency Provisions.
Lehigh Cement Company Page 3 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Comment 4 

The cover page of both the Draft Permit and Source Modifications fails to reference 

Minor Permit Modification No. 093-21919-00002 that has been proposed to U.S. 

EPA. Certain of the following comments have been raised and addressed in the 

Minor Permit Modification; however, because IDEM: (1) did not wait to public notice 

the Draft Permit and Source Modifications until after issuance of the Minor Permit 

Modification; (2) did not simply incorporate the Draft Permit and Source Modification 

changes to the version of Lehigh’s Part 70 Operating Permit proposed to U.S. EPA; 

and (3) because certain conditions in the public-noticed Draft Permit and Source 

Modifications differ from those agreed to in the Minor Permit Modification, Lehigh will 

repeat the same comments again in response to this public notice to ensure the 

necessary changes are made. 

Response 4 

 

Minor Permit Modification 093-21919-00002 was issued on April 17, 2006 and has 

been referenced on the cover page of Significant Source Modification 089-21793-

00002 and Significant Permit Modification 089-21975-00002. 

Comment 5 

The Conditions Affected Sections of the Draft Permit and Source Modifications do not 

adequately identify the conditions of Lehigh’s Part 70 Operating Permit that are 

affected by the modifications. Given that appeals of Lehigh’s Part 70 Operating 

Permit are pending with the Indiana Office of Environmental Adjudication, it is 

especially important to clarify exactly which conditions are being modified. A simple 

reference to Sections D.1, D.2, D.3, D.4, D.5 and D.7 of the Part 70 Permit is wholly 

inadequate. Please modify the Conditions Affected Sections consistent with these 

comments as follows: 

Conditions Affected: Table of Contents B.25, C.20, and C.21; Kiln #1 and Kiln #2 

Facility Descriptions in Section A.2(ccc), A.2 (ddd), and D.4; 

Amended IDEM’s address in Sections B.10(a), B.11(a), 

B.12(b)(5), B.15(b), B.17(a), B.18(b), B.20(a)(4), B.23(b), C.8(d), 

C.9(a), C.11, C.19(b), C.21(b), C.22(f), and on the Emergency 

Occurrence Report Form; Conditions B25, C.20, C.21, D.2.9(c), 

D.2.11(a), and D.4.1.1. 

Lehigh assumes that its few remaining comments to Minor Permit Modification No. 

093-21919-00002 will be addressed prior to issuance and that the Minor Permit 

Modification will be issued prior to the Significant Permit and Source Modifications, 

thus creating the need to only modify the above-referenced conditions. 

Response 5 

The identifications in the Conditions Affected Section of the Significant Source 

Modification and the Significant Permit Modification permits have been modified to 

read as follows: 

Conditions Affected: Table of Contents B.25, C.20, and C.21; Kiln #1 and Kiln #2 

Facility Descriptions in Section A.2(ccc), A.2 (ddd), and D.4; 

Amended IDEM’s address in Sections B.10(a), B.11(a), 

B.12(b)(5), B.15(b), B.17(a), B.18(b), B.20(a)(4), B.23(b), C.8(d), 

C.9(a), C.11, C.19(b), C.21(b), C.22(f), and on the Emergency 

Occurrence Report Form; Conditions B25, C.20, C.21, D.2.9(c), 

D.2.11(a), and D.4.1.1. 
Lehigh Cement Company Page 4 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Comment 6 

Please note that the following comments detailing specific changes to permit 

conditions are intended to apply not only to the Draft Significant Permit Modification, 

but also to the Draft Significant Source Modification (as the Source Modification 

includes/attaches a copy of the permit conditions). In that accord, the conditions of 

Draft Significant Permit Modification and the Draft Significant Source Modification

should be identical; however this is not the case as public noticed. See the DeltaView 

generated red-lined pages of the changes existing between the Draft Significant 

Permit Modification and the Draft Significant Source Modification, attached as

Attachment C. 

In addition, the conditions B.20, D.2.11(b), Facility Description D.4 and D.7.10(e) 

should be identical in the Significant Permit Modification and the Significant Source 

Modification. 

Please modify the Draft Significant Permit Modification and the Draft Significant 

Source Modification so the conditions are consistent with the comments below and 

modify the Draft Source Modification consistent with the Draft Permit Modification. 

Attachment C changes are listed and addressed below or elsewhere in this ATSD. 

D.2.3 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

 Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), the visible 

 emissions from the material storage building (F03), each of the raw mills (EU11, 

 EU11A, EU12, and EU12A), and each conveying system transfer point associated with 

 the Kiln #1 and Kiln #2 alternative fuel delivery systems (F19 and F20) shall each not 

 exceed ten percent (10%) opacity. 

D.2.9 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] [40 CFR 63, Subpart 

LLL] 

(a) Within 180 days after startup June 14, 2002, which is the compliance date for 

the Portland Cement Manufacturing Industry NESHAP, the Permittee shall 

demonstrate initial compliance with the limit established in Condition D.2.3 for the

material storage building (F03) and the raw mills (EU11, EU11A, EU12, EU12A),

by conducting a test in accordance with 40 CFR 63.1349 and Method 9 of 40 

CFR Part 60, Appendix A. Testing shall be conducted in accordance with

Section C - Performance Testing. 

(c) Within 180 days after start up of each of the alternative fuel delivery systems 

(F19 and F20), the Permittee shall demonstrate initial compliance with the 

opacity limit established in Condition D.2.3 by conducting a test in accordance

with 40 CFR 63.1349(b)(2) and Method 9 of 40 CFR Part 60, Appendix A. 

Testing shall be conducted in accordance with Section C - Performance Testing. 

D.2.11 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

 Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a 

 written operations and maintenance plan for the material storage building (F03) and 

 each of the raw mills (EU11, EU11A, EU12 and EU12A) by June 14, 2002, which is the 

 compliance date for the National Emission Standards for Hazardous Air Pollutants 

 (NESHAP) from the Portland Cement Manufacturing Industry.; and for the conveyor 

 transfer points associated with the Kiln #1 alternative fuel delivery system (F19) 

 and the conveyor transfer points associated with the Kiln #2 alternative fuel 

 delivery system (F20), upon startup of operations. 

 Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a 

 written operations and maintenance plan for each conveyor transfer point associated
Lehigh Cement Company Page 5 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

 with the Kiln #1 and Kiln #2 alternative fuel delivery systems, upon start up. 

 

D.2.14 Broken or Failed Bag Detection 

 In the event that bag failure has been observed. 

 (a) For a single compartment baghouse, controlling emissions from a process 

operated continuously, failed units and the associated process shall be shut

down immediately until the failed units have been repaired or replaced. 

Operations may continue only if the event qualifies as an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this permit 

(Section B - Emergency Provisions). 

D.3.11 Visible Emissions Notations .

(e) If abnormal emissions are observed, the Permittee shall take reasonable 

response steps in accordance with Section C - Response to Excursions or

Exceedances. Failure to take response steps in accordance with Section C - 

Response to Excursions or Exceedances shall be considered a deviation 

violation of this permit. 

D.3.12 Parametric Monitoring

The Permittee shall record the pressure drop across each baghouse associated with the

raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the clinker handling facilities/emission units (EU25,

EU26a, EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill 

facilities/emission units (EU32 through EU36 and EU38), and the finish material storage

and bulk loading and packaging facilities/emission units (EU37, EU39 through EU47) at

least once per day when the associated facility/emission units are in operation and 

venting to the atmosphere. The Permittee shall record the pressure drop across all other 

baghouses at least once per day when the associated facility/emission units are in 

operation and venting to the atmosphere. When for any one reading, the pressure drop

across a baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range

established during the latest stack test, the Permittee shall take reasonable response

steps in accordance with Section C - Response to Excursions or Exceedances. A

pressure reading that is outside the above mentioned range is not a deviation from this

permit. Failure to take response steps in accordance with Section C - Response to 

Excursions or Exceedances, shall be considered a deviation violation of this permit. 

Response 6 

 

In order to be consistent with Minor Permit Modification 093-21919-00002, D.2.3 and 

D.2.15 in the SPM 093-21975-00002 and the SSM 093-21793-00002 shall remain 

unchanged. 

IDEM has modified Condition D.2.3 of the SSM 093-21793-00002 to be consistent with 

SPM 093-21975-00002 and the Minor Permit Modification 093-21919-00002. 

In addition, all other conditions in the Significant Permit Modification No. 093-21975-

00002 and Significant Source Modification No. 093-21793-00002 have been made 

identical, and discrepancies between conditions included in the two documents, as public

noticed, have been removed. 

Consistent with Minor Permit Modification 093-21919-00002, D.2.9, D.3.11, and D.3.12 of the 

SPM 093-21975-00002 and the SSM 093-21793-00002 have been changed to read as follows: 

D.2.9 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] [40 CFR 63, 

 Subpart LLL]

(a) Within 180 days after startup June 14, 2002, which is the compliance date for 

the Portland Cement Manufacturing Industry NESHAP, the Permittee shall 
Lehigh Cement Company Page 6 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

demonstrate initial compliance with the limit established in Condition D.2.3 for the

material storage building (F03) and the raw mills (EU11, EU11A, EU12, EU12A),

by conducting a test in accordance with 40 CFR 63.1349 and Method 9 of 40 

CFR Part 60, Appendix A. Testing shall be conducted in accordance with

Section C - Performance Testing. 

(c) Within 180 days after start up of each of the alternative fuel delivery systems 

(F19 and F20), the Permittee shall demonstrate initial compliance with the limit 

established in Condition D.2.3 by conducting a test in accordance with 40 CFR 

63.1349(b)(2) and Method 9 of 40 CFR Part 60, Appendix A. Testing shall be 

conducted in accordance with Section C - Performance Testing. 

D.3.11 Visible Emissions Notations 

(e) The Compliance Response Plan for these units shall contain troubleshooting

contingency and response steps for when an abnormal emission is observed. 

Failure to take response steps in accordance with Section C - Compliance

Response Plan - Preparation, Implementation, Records, and Reports, shall be

considered a violation of this permit.

D.3.12 Parametric Monitoring

The Permittee shall record the pressure drop across each baghouse associated with the 

raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the 

con¬veyor transfer points associated with the clinker handling facilities/emission units 

(EU25, EU26a, EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill 

facilities/emission units (EU32 through EU36 and EU38), and the finish material storage 

and bulk loading and packaging facilities/emission units (EU37, EU39 through EU47) at 

least once per day when the associated facility/emission units are in operation and 

venting to the atmosphere. The Permittee shall record the pressure drop across all other 

baghouses at least once per day when the associated facility/emission units are in 

operation and venting to the atmosphere. When for any one reading, the pressure drop 

across a baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range 

established during the latest stack test, the Permittee shall take reasonable response 

steps in accordance with Section C - Response to Excursions or Exceedances. A

pressure reading that is outside the above mentioned range is not a deviation from this 

permit. Failure to take response steps in accordance with Section C - Response to 

Excursions or Exceedances, shall be considered a deviation violation of this permit. 

 

Both the SPM 093-21975-00002 and the SSM 093-21793-00002 have been changed to read as 

follows: 

D.2.11 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

 (a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare 

 a written operations and maintenance plan for the material storage building (F03) and 

each of the raw mills (EU11, EU11A, EU12 and EU12A) by June 14, 2002, which is 

the compliance date for the National Emission Standards for Hazardous Air 

Pollutants (NESHAP) from the Portland Cement Manufacturing Industry.; and for the 

conveyor transfer points associated with the Kiln #1 alternative fuel delivery

system (F19) and the conveyor transfer points associated with the Kiln #2

alternative fuel delivery system (F20), upon startup of operations. 

 Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare 

 a written operations and maintenance plan for each conveyor transfer point

 associated with the Kiln #1 and Kiln #2 alternative fuel delivery systems, upon start 

 up. 

 
Lehigh Cement Company Page 7 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Comment 7 

Please change “coal and clean or treated wood” in the second paragraphs of Sections 

A.2(ccc) and (ddd) to “coal and clean and/or treated wood.” 

Response 7 

The second paragraphs of Sections A.2(ccc) and (ddd) of the Significant Source 

Modification No. 093-21793-00002 and Significant Permit Modification No. 093-21975-

00002 have been changed to read “coal and clean and/or treated wood”. 

(ccc) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and 

modified to a one-stage preheater kiln in July 2003, with a heat input rate of 

118 million Btu per hour, with a nominal production rate of 38 tons per hour, 

with PM emissions controlled by one (1) electrostatic precipitator (ESP), 

identified as KP1, and dioxins/ furans controlled and SO2 partially controlled by 

a Water Spray Tower, and exhausting to one (1) stack, identified as S-KP1. 

Kiln #1 is also permitted to use a blended fuel of coal and pressed paper 

making waste where the blend has a maximum of 20% pressed paper making 

waste by heat input. 

Kiln #1 is permitted to use a blended fuel of coal and clean and/or treated wood 

where the blend has a maximum of up to 35% clean and/or treated wood by 

heat input. 

(ddd) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and 

modified to a one-stage preheater kiln in July 2003, with a heat input rate of 

118 million Btu per hour, with a nominal production rate of 38 tons per hour, 

with PM emissions controlled by one (1) electrostatic precipitator (ESP), 

identified as KP2, and dioxins/ furans controlled and SO2 partially controlled by 

a Water Spray Tower, and exhausting to one (1) stack, identified as S-KP1. 

Kiln #2 is also permitted to use a blended fuel of coal and pressed paper 

making waste where the blend has a maximum of 20% pressed paper making 

waste by heat input. 

Kiln #2 is permitted to use a blended fuel of coal and clean and/or treated wood 

where the blend has a maximum of up to 35% clean and/or treated wood by 

heat input.

Comment 8 

Delete the unilateral changes made to Conditions B.11; B.12; B.20; C.12; C.14; C.17; 

D.1.4; D.1.5; D.1.7; D.1.8; D.1.9; D.1.10; D.1.11; D.2.10; D.2.12; D.2.13; D.2.14; D.2.15; 

D.2.16; D.3.9; D.3.11; D.3.12; D.3.13; D.3.14; D.3.15; D.4.9; D.4.14; D.4.15; D.5.9; 

D.5.11; D.5.12; D.5.13; D.5.14; D.5.15; D.7.7; D.7.10; and D.7.11 of Lehigh’s existing 

Part 70 Operating Permit. Lehigh’s Treated Wood Application did not include a request 

to modify these conditions, nor is modification necessary for approval of said application. 

 Moreover, as stated in Comment #1, Lehigh appealed its Initial Part 70 Operating Permit, 

its First Significant Permit Modification and its Second Significant Permit Modification to 

the Indiana Office of Environmental Adjudication (“OEA”) and has agreed to be bound by 

the Joint Stipulations of Stay of Effectiveness in Cause Nos. 03-A-J-3010 and 04-A-J3480. Lehigh would like to avoid having to appeal its Significant Permit and Source 

Modifications Nos. 093-21975-00002 and 093-21793-00002 to clarify the amendments to 

its existing Part 70 Operating Permit and the effectiveness of the terms and conditions of 

its existing stay agreements and previously issued permits, and/or to correct errors in the 

proposed language. 
Lehigh Cement Company Page 8 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Response 8 

In the draft SSM No. 093-21793-00002 and SPM No. 093-21975-00002 that was on 

Public Notice, Conditions B.11; B.12; B.20; C.12; C.14; C.17; D.1.4; D.1.5; D.1.7; D.1.8; 

D.1.9; D.1.10; D.1.11; D.2.10; D.2.12; D.2.13; D.2.14; D.2.15; D.2.16; D.3.9; D.3.11; 

D.3.12; D.3.13; D.3.14; D.3.15; D.4.9; D.4.14; D.4.15; D.5.9; D.5.11; D.5.12; D.5.13; 

D.5.14; D.5.15; D.7.7; D.7.10; and D.7.11 were modified, as shown in the Technical 

Support Document for SSM No. 093-21793-00002 and SPM No. 093-21975-00002 (listed 

under Changes No. 1 through 6). These modifications were made in order to address 

routinely appealed permit conditions in Title V permits. 

IDEM has reconsidered the decision to make these revisions to Conditions B.11; B.12; 

B.20; C.12; C.14; C.17; D.1.4; D.1.5; D.1.7; D.1.8; D.1.9; D.1.10; D.1.11; D.2.10; D.2.12; 

D.2.13; D.2.14; D.2.15; D.2.16; D.3.9; D.3.11; D.3.12; D.3.13; D.3.14; D.3.15; D.4.9; 

D.4.14; D.4.15; D.5.9; D.5.11; D.5.12; D.5.13; D.5.14; D.5.15; D.7.7; D.7.10; and D.7.11 

of Lehigh’s existing Part 70 Operating Permit No. T093-5990-00002. 

Comment 9 

Condition B.25 does not accurately incorporate 326 IAC 1-1-6 into Lehigh’s Part 

70 Operating Permit. Consistent with 326 IAC 1-1-6, please modify Condition 

B.25 as follows: 

 

B.25 Credible Evidence [326 IAC 1-1-6] 

For the purpose of submitting compliance certifications or establishing whether or 

not the Permittee has violated or is in violation of any emission limitation, 

standard, or rule in Title 326 of the Indiana Administrative Code, nothing in Title 

326 of the Indiana Administrative Code shall preclude the use, including the 

exclusive use, of any credible evidence or information relevant to whether the 

Permittee would have been in compliance with the emission limitation, standard, 

or rule, if the appropriate performance or compliance test procedure had been 

performed. 

Response 9 

 Condition B.25 has been modified as follows: 

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-1-6] 

For the purpose of submitting compliance certifications or establishing whether or 

not the Permittee has violated or is in violation of any condition of this permit any 

emission limitation, standard, or rule in Title 326 of the Indiana 

Administrative Code, nothing in this permit Title 326 of the Indiana 

Administrative Code shall preclude the use, including the exclusive use, of any 

credible evidence or information relevant to whether the Permittee would have 

been in compliance with the condition of this permit emission limitation, 

standard, or rule, if the appropriate performance or compliance test procedure 

had been performed. 

Comment 10 

 

Delete Condition C.20(c) and C.21(f), (g) and (h) because these modifications do not 

apply to Lehigh’s treated wood modification, do not have to be incorporated at this time, 

and will nonetheless have to be further modified given the D.C. Circuit Court of Appeals’ 

June 24, 2005 decision in New York v. EPA. 
Lehigh Cement Company Page 9 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Response 10 

Conditions C.20(c) and C.21(f), (g) and (h) are NSR reform rules that apply to major 

sources under 326 IAC 2-2 (Prevention of Significant Deterioration) and 326 IAC 2-3 

(Emission Offset). Lehigh Cement Company is a major source under 326 IAC 2-2, and 

therefore these conditions have not been deleted. 

 

Comment 11 

Since the facility description box for Section D.2 and Section D.3 of the proposed permit 

now appears in two separate boxes on two separate pages of the proposed permit, 

consistent with the other Facility Description Boxes in Lehigh’s existing Part 70 Operating 

Permit, each box on each page should include the following statement: “(The information 

describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.)” 

 Response 11 

The facility description boxes in Sections D.2 and D.3 of the permit have been changed 

as requested. 

SECTION D.2 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The raw mill facilities/emissions units, as follows: 

(1) One (1) raw mill #1, identified as EU11, constructed in 1961, with a nominal rate of 100 tons 

per hour and including a natural gas-fired burner, identified as EU11A, with a maximum heat 

input capacity of 20 million British thermal units (MMBtu) per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC3, and exhausting to one (1) stack, identified 

as S-RMDC3. 

(2) - - - - - - - 

(The information describing the processes contained in this facility description box is 

descriptive information and does not constitute enforceable conditions.)

SECTION D.3 

The finish mill facilities/emissions units, as follows: 

(1) One (1) finish mill #1 with associated feed bin, identified as EU32, constructed in 1959, with a 

nominal rate of 37 tons per hour, with PM emissions controlled by one (1) baghouse, identified 

as RMDC5 and RMDC6, and each exhausting to separate stacks, identified as S-RMDC5 and SRMDC6, respectively. 

(2) - - - - - - 

 (The information describing the processes contained in this facility description box is 

descriptive information and does not constitute enforceable conditions.) 

Comment 12 

 Condition D.2.11(a)(2) should reference the conveyor transfer points associated with the 

 Kiln #1 and Kiln #2 alternative fuel delivery systems (emphasis added.) 

Also, consistent with 40 CFR § 63.1350(a)(4) paragraphs (a)(2)(E) – (F) in Condition 

D.2.11 should not be included as subsections under: “The plan shall include the 

following.” Instead said paragraphs should be flush with the text of (a). 
Lehigh Cement Company Page 10 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

 Additionally, please delete the second paragraph of Condition D.2.11(b) which incorrectly 

requires daily visible emission observations of the conveyor transfer points associated

with the Kiln #1 and Kiln #2 alternative fuel delivery systems (F19 and F20). Pursuant to 

40 C.F.R. § 63.1350(a)(4)(i)-(vii) the monitoring requirements for the conveyor system 

transfer points associated with the Kiln #1 and Kiln #2 alternative fuel delivery systems 

(F19 and F20) are already set forth in Condition D.2.11(a)(2). 

Therefore, as commented on in response to Minor Modification Permit No. 093-21919-

00002, please modify Condition D.2.11 as follows: 

Response 12

 Condition D.2.11 has been changed to read as follows: 

D.2.11 NESHAP Monitoring Requirements [40 CFR 63, Subpart LLL] 

(a) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall 

prepare a written operations and maintenance plan for the material storage building 

(F03) and each of the raw mills (EU11, EU11A, EU12 and EU12A) by June 14, 

2002, which is the compliance date for the National Emission Standards for 

Hazardous Air Pollutants (NESHAP) from the Portland Cement Manufacturing 

Industry; and for the conveyor transfer points associated with the Kiln #1 alternative 

fuel delivery system (F19) and the conveyor transfer points associated with the Kiln 

#2 alternative fuel delivery system (F20), upon startup of operations.

 The plan shall include the following information: 

(1) Procedures for proper operation and maintenance of the affected

sources and associated air pollution control device(s) in order to meet

the emissions limit in Condition D.2.3; and 

(2) Procedures to be used to periodically monitor the material storage

building (F03), and the conveyor transfer points associated with the Kiln 

#1 and Kiln #2 alternative fuel delivery systems (F19 and F20), which 

are subject to opacity standards under 40 CFR 63.1348. Such

procedures must include the following provisions: 

(A) The Permittee shall conduct a monthly 1-minute visible 

emissions test of each affected source in accordance with 40

CFR 60, Appendix A, Method 22. The test must be conducted 

while the affected source is in operation. 

(B) If no visible emissions are observed in six consecutive monthly 

tests for any affected source, the Permittee may decrease the

frequency of testing from monthly to semi-annually for that 

affected source. If visible emissions are observed during any 

semi-annual test, the Permittee shall resume testing of that 

affected source on a monthly basis and maintain that schedule

until no visible emissions are observed in six consecutive

monthly tests. 

(C) If no visible emissions are observed during the semi-annual test

for any affected source, the Permittee may decrease the

frequency of testing from semi-annually to annually for that 

affected source. If visible emissions are observed during any 

annual test, the Permittee shall resume testing of that affected

source on a monthly basis and maintain that schedule until no

visible emissions are observed in six consecutive monthly tests. 
Lehigh Cement Company Page 11 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

(D) If visible emissions are observed during any Method 22 test, the 

Permittee must conduct a 6-minute test of opacity in accordance 

with 40 CFR 60, Appendix A, Method 9. The Method 9 test must 

begin within one hour of any observation. 

(3) Corrective actions to be taken when required by paragraph (b). 

(A) The requirement to conduct Method 22 visible emissions monitoring under 

Section D.2.11(a)(2) above, shall not apply to any totally enclosed 

conveying system transfer point that is operated and maintained as total 

enclosures on a continuing basis in accordance with the facility 

operations and maintenance plan, regardless of the location of the transfer 

point. “Totally enclosed conveying system transfer point” shall mean a 

conveying system transfer point that is enclosed on all sides, top, and 

bottom. The enclosures for these transfer points shall be operated and 

maintained as total enclosures on a continuing basis in accordance with the 

facility operations and maintenance plan. 

(B) If any partially enclosed or unenclosed conveying system transfer point is 

 located in a building, the Permittee shall have the option to conduct a 

 Method 22 visible emissions monitoring test according to the requirements of 

 paragraphs (a)(2)(A) through (D) of this section for each such conveying 

 system transfer point located within the building, or for the building itself, 

 according with the paragraph below. 

(C) If visible emissions from a building are monitored, the requirements of 

paragraphs (a)(2)(A) through (D) of this section apply to the monitoring of the 

building, and the Permittee shall also test visible emissions from each side, 

roof and vent of the building for at least 1 minute. The test must be 

conducted under normal operating conditions. 

(D) Failure to comply with any provision of the operations and maintenance plan 

shall be a violation of the standard. The contents of the operations and 

maintenance plan are not included in this permit and may be modified by the 

Permittee without modification or amendment of this permit. 

(b) Pursuant to 40 CFR 63.1350 (Monitoring Requirements), on and after June 

 14, 2002, the Permittee shall monitor opacity from the raw mills (EU11, 

 EU11A, EU12 and EU12A) by conducting daily visual emissions observations 

 of the mill sweep and air separator particulate matter control devices 

 (PMCDs), in accordance with the procedures of 40 CFR 60, Appendix A, 

 Method 22. The Method 22 test shall be conducted while the affected source 

 is operating at representative performance conditions. The duration of the 

 Method 22 test shall be six minutes. If visible emissions are observed during 

 any Method 22 visible emissions test, the Permittee must: 

(1) Initiate, within one (1) hour, the corrective actions specified in the site 

specific operations and maintenance plan developed in accordance with 

40 CFR §§ 63.1350(a)(1) and (a)(2). 

(2) Within twenty-four (24) hours of the end of the Method 22 test in which 

visible emissions were observed, conduct a follow-up Method 22 test of 

each stack from which visible emissions were observed during the 

previous Method 22 test. If visible emissions are observed during the 

follow-up Method 22 test from any stack from which visible emissions 

were observed during the previous Method 22 test, conduct a visual 

opacity test of each stack from which visible emissions were observed 

during the follow-up Method 22 test in accordance with 40 CFR Part 60, 
Lehigh Cement Company Page 12 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Appendix A, Method 9. The duration of the Method 9 test shall be thirty 

minutes. 

Comment 13 

 Please change “coal and clean or treated wood” in the second paragraphs of Facility 

Descriptions (1) and (2) in Section D.4 to “coal and clean and/or treated wood.” 

 Response 13 

Section D.4 (Facility Descriptions 1 and 2) of the Significant Source Modification and 

Significant Permit Modification has been changed to read as follows: 

Section D.4 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The kiln facilities/emissions units, as follows: 

(1) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a 

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP1, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #1 is also permitted to use a blended fuel of coal and pressed paper making waste 

where the blend has a maximum of 20% pressed paper making waste by heat input. 

Kiln #1 is permitted to use a blended fuel of coal and clean and/or treated wood where the 

blend has a maximum of up to 35% clean and/or treated wood by heat input. 

(2) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a 

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP2, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #2 is also permitted to use a blended fuel of coal and pressed paper making waste 

where the blend has a maximum of 20% pressed paper making waste by heat input. 

 

 Kiln #2 is permitted to use a blended fuel of coal and clean and/or treated wood where the 

blend has a maximum of up to 35% clean and/or treated wood by heat input. 

(3) One (1) kiln #3, identified as EU17, constructed in 1974 as a one-stage preheater kiln, with a 

heat input rate of 118 million Btu per hour, with a nominal production rate of 43 tons per hour, 

with PM emissions controlled by one (1) electrostatic precipitator (ESP), identified as KP3, and 

exhausting to one (1) stack, identified as S-KP2. Kiln #3 is also permitted to use a blended 

fuel of coal and pressed paper making waste where the blend has a maximum of 20% pressed 

paper making waste by heat input. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

Comment 14 

The modification to the last sentence of Condition D.4.1, changing “are” to “is” is 

incorrect. Please do not modify existing Condition D.4.1. 

Response 14 

The last sentence in Condition D.4.1 of the Significant Source Modification and 

Significant Permit Modification will be changed to read as follows: 
Lehigh Cement Company Page 13 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Therefore, the requirements of 326 IAC 2-2 (PSD) is are not applicable to the preheater 

modification. 

Comment 15 

Consistent with the Minor Permit Modification No. 093-21919-00002 issued on April 17, 

2006, Lehigh’s permit application and emission calculations, Condition D.4.1.1 should 

reference “326 IAC 2-2-2(d)(3)” rather than “326 IAC 2-2-2-(d)(4)” because Lehigh 

utilized the actual-to-projected-actual applicability test to determine if the treated wood 

project modification to the existing Kilns #1 and #2 would trigger PSD review. 

Additionally, please change both references to “clean or treated wood” in Condition 

D.4.1.1 to “clean and/or treated wood.” 

Response 15 

Condition D.4.1.1 of the Significant Source Modification and Significant Permit 

Modification will be changed to read as follows: 

D.4.1.1 Kiln #1 and Kiln #2 Partial Fuel Switch [326 IAC 2-2-2(d)( 4 3)]

Pursuant to 326 IAC 2-2-2(d)(4 3), Kiln #1 and Kiln #2 are permitted to burn a blended 

fuel of coal and clean and/or treated wood where the blend has a maximum of up to 35% 

clean and/or treated wood by heat input. 

Comment 16 

 Please modify the Technical Support Document (“TSD”) in the Addendum to the TSD to 

accompany the final permit, consistent with the comments above and the red-lined 

comments to the public-noticed TSD attached as Attachment D. 

Response 16 

No changes will be made to the TSD because the OAQ prefers that the Technical 

Support Document reflect the permit that was on public notice. Changes to the permit or 

technical support material that occur after the public notice period are documented in this 

Addendum to the Technical Support Document. 

(a) The issuance of the Minor Permit Modification No. 093-21919-00002 has been 

included in the cover pages of the SSM No. 093-21793-00002 and SPM No. 093-

21975-00002. 

(b) The PM and PM-10 potential to emit of the modified emission units included in 

SSM No. 093-21793-00002 has not changed. Therefore, the OAQ does not 

agree to make changes to the table titled “Potential to Emit of Modification” as 

proposed in Appendix D. 

(c) The proposed changes to the table titled “Potential to Emit of Modification After 

Issuance” have been noted and documented: 

 Potential to Emit (tpy) * 

 CO NOx SO2 VOC PM PM10 Pb HAPs 

Potential to Emit 

before 

Modification 

(tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54397 17.78

18.32 

Potential to Emit 

after 

Modification 

(tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54397

6

17.78

18.32 

Net Emission 

Increase (tpy) 

 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 
Lehigh Cement Company Page 14 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

 NSR Project Evaluation (tpy) * 

Process/facility PM PM-10 SO2 VOC CO NOX Pb HAPs 

Adjusted

Baseline 

Actual 

Emissions 

 66.33 139.76 1,778.93 63.96 395.59 2,638.79 0.01671 13.20 

Projected 

Actual 

Emissions 

 55.78 74.53 1,340.61 9.66 486.03 1,482.23 0.02253 17.78 

Net Emission -10.55 -65.23 -438.32 -54.30 90.44 -1,156.56 0.00582 4.58 

PSD 

Threshold 

Level 

 25 15 40 40 100 40 0.60 10 

Single 

25 All 

• Emissions provided by the source and based on adjusted baseline actual emissions 

for CO, NOx, SO2, VOC, PM, PM10 for the time period of April 1998 through March 

2000. Adjusted bBaseline actual emissions for Pb are based on the time period of 

August 2003 through July 2005. Adjusted bBaseline actual emissions for HAPs are 

based on the time period of July 2003 through June 2005 using U.S. EPA AP-42 

emission factors for preheater kilns. 

(d) The OAQ does not agree to make changes to language related to the Actual to 

Projected Actual (ATPA) test in 326 IAC 2-2-2. This source is major under 326 

IAC 2-2 (PSD), and the ATPA test is an applicable provision for major PSD 

sources. 

(e) The proposed changes to the section titled “Federal Rule Applicability” have 

been noted. The changes to Condition D.2.11, as documented under Response 

6, adequately address this comment. 

(f) The proposed deletion of the nonapplicability of 326 IAC 2-4.1-1 (Air Toxics 

Control) has been noted. No change has been made as a result of this comment. 

(g) The proposed change to the applicability of 326 IAC 6-3-2 to the alternative fuel 

delivery systems F19 and F20 is noted. No change has been made to condition 

D.2.1(e) which states: 

“Pursuant to 326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing 

 Processes), the allowable particulate emissions rate from the Kiln #1 alternative 

fuel delivery system (F19), shall not exceed 19.2 pounds per hour when 

operating at a process weight rate of 10 tons per hour.” 

(h) The proposed changes to the TSD section titled “Compliance Requirements” 

have been noted, however, no changes have been made to the permit as a result 

of this comment. 

Comment 17 

 Please modify Appendix A – Emission Calculations as set forth in Attachment E. 

 

Response 17 

The TSD Appendix A – Emissions Calculations have not been changed, since the OAQ 

prefers that the Technical Support Document reflect the permit that was on public notice. 

The requested changes in the emissions calculations have been noted, and are 

documented in this Addendum as follows: 
Lehigh Cement Company Page 15 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

 NSR Project Evaluation (tpy) * 

 CO NOx SO2 VOC PM PM10 Pb HAPs 

Adjusted 

Baseline Actual 

Emissions 

395.59 2,638.79 1,778.93 63.96 66.33 139.76 0.01671 13.20 

Projected 

Actual 

Emissions 

486.03 1,482.23 1,340.61 9.66 55.78 74.53 0.02253 17.78 

Net Emissions 90.44 -1,156.56 -438.32 -54.30 -10.55 -65.23 0.00582 4.58 

PSD Threshold 

Level 

 100 40 40 40 25 15 0.60 10 

single 

25 all 

* Emissions provided by the source and based on adjusted baseline actual emissions for CO, 

 

 NOx, SO2, VOC, PM, and PM10 and HAPs for time period April 1998 through March 2000. 

 Adjusted bBaseline actual emissions for Pb is based on time period August 2003 through July 

 2005. 

 Adjusted bBaseline actual emissions for HAPs are based on the time period July 2003 through 

 June 2005. 

 Potential to Emit (tpy) * 

 CO NOx SO2 VOC PM PM10 Pb HAPs 

Potential to Emit 

before 

Modification (tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54397 17.78

18.32 

Potential to Emit 

after Modification 

(tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54397

6

17.78

18.32 

Net Emission 

Increase (tpy) 

 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

The PM and PM10 emissions increase from conveying treated wood has been accounted 

for in the clean wood permit (093-21919-00002). Therefore, IDEM believes there should 

be no change in PM and PM10 shown between PTE before the Modification and PTE 

after the Modification. 

On April 13, 2006, Lehigh Cement Company submitted comments on the approved Minor 

Source Modification. Where they are pertinent to the Significant Permit Modification 089-

21975-00002 and Significant Source Modification 089-21793-00002 these changes will 

be made. A summary of the comments and the IDEM response is as follows (bold 

language has been added and language with a line through it has been deleted): 

Comment 18 

 Condition D.2.9(C) should cite to “40 CFR 63.1349(b)(2)” not to “40 CFR 63.1349(b)(C).” 

Response 18 

 Condition D.2.9(C) will be modified to read: 

D.2.9 Testing Requirements [326 IAC 2-7-6(1),(6)] [326 IAC 2-1.1-11] [40 CFR 63, Subpart LLL] 

(c) Within 180 days after start up of each of the alternative fuel delivery systems 

(F19 and F20), the Permittee shall demonstrate initial compliance with the limit 

established in Condition D.2.3 by conducting a test in accordance with 40 CFR 

63.1349(b)(C2) and Method 9 of 40 CFR Part 60, Appendix A. Testing shall be 

conducted in accordance with Section C - Performance Testing. 
Lehigh Cement Company Page 16 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Comment 19 

Please correct Condition D.7.11, by labeling the last paragraph “(e)” instead of “(d)”. 

Response 19 

D.7.11 Record Keeping Requirements [326 IAC 20-27] [40 CFR 63.1355] 

(a) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the 

Permittee shall maintain all records required by 40 CFR 63.1355. These records 

include the following: 

(1) The Permittee shall maintain files of all information (including all reports 

and notifications) required by 40 CFR 63.1355(a) recorded in a form 

suitable and readily available for inspection and review as required by 40 

CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as 

required by 40 CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications 

of compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting 

analyses. 

(b) To document compliance with Condition D.7.4, the Permittee shall maintain 

records of the material input to each process at the calcium sulfate material 

facilities/emission units. Records shall be complete and sufficient to demonstrate 

compliance with Condition D.7.4. 

(c) To document compliance with Condition D.7.5, the Permittee shall maintain 

records of any additional inspections prescribed by the Preventive Maintenance 

Plan. 

(d) To document compliance with Condition D.7.10, the Permittee shall maintain 

records of visible emission notations of the calcium sulfate material 

facilities/emission units, including the synthetic gypsum hopper (F11), synthetic 

gypsum weight belt (F15), raw material hopper (F13), raw material weight belt 

(F16), main belt #1 (F17), CKD storage silo (EU48), main belt #2 (F18), and all 

transfer points once per shift. 

(d e) All records shall be maintained in accordance with Section C - General Record 

Keeping Requirements, of this permit. 

Comment 20 

 Consistent with 326 IAC 2-2-8(b)(5)(D) and 50 CFR 51.165(a)(6)(v)(C), Condition 

C.21(g)(4) should be corrected to state as follows: “Any other information that the 

Permittee wishes to include in the report.” 

Response 20 

 Condition C.21(g)(4) has been modified as follows: 

 (4) Any other information that the Permittee deems fit to include in this report,

 Any other information that the Permittee wishes to include in the report. 
Lehigh Cement Company Page 17 of 17 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: W. Habeeb SPM 093-21975-00002

Comment 21 

 The references to the “alternate fuel delivery systems” in Conditions D.2.2 and D.2.3 

should be corrected to “alternative fuel delivery systems.” 

Response 21 

 Conditions D.2.2 and D.2.3 have been modified as follows: 

D.2.2 General Provisions Relating to NESHAP [326 IAC 20-1][40 CFR Part 63, Subpart A] 

 The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are 

incorporated by reference in 326 IAC 20-1, apply to the material storage building (F03), 

the raw mills (EU11, EU11A, EU12 and EU12A), and each conveying system transfer 

point associated with the Kiln #1 and Kiln #2 alternate alternative fuel delivery systems 

(F19) and (F20) described in this section except when otherwise specified in 40 CFR Part 

63, Subpart LLL. 

 

D.2.3 NESHAP Emissions Limitation [40 CFR 63, Subpart LLL] 

 Pursuant to 40 CFR 63.1348 (Emissions Standards and Operating Limits), the visible 

emissions from the material storage building (F03), each of the raw mills (EU11, EU11A, 

EU12 and EU12A), and each conveying system transfer point associated with the Kiln #1 

and Kiln #2 alternate alternative fuel delivery systems (F19) and (F20) shall each not 

exceed ten percent (10%) opacity. 

Comment 22 

 Please correct the typographical error in C.20(c)(1)(C)(iii) (an apostrophe) and in 

C.20(c)(3), (“toms per year”). 

Response 22 

 The typographical errors have been corrected. 

Other Changes

 IDEM’s address in Conditions B.10(a), B.11(a), B.12(b)(5), B.15(b), B.17(a), B.18(b), 

B.20(a)(4), B.23(b), C.8(d), C.9(a), C.11, C.19(b), C.21(b), C.22(f), and on the 

Emergency Occurrence Report form has been changed to: 

 Indiana Department of Environmental Management 

Compliance Branch, Office of Air Quality 

100 North Senate Avenue, 

Indianapolis, Indiana 46204-2251
Indiana Department of Environmental Management

Office of Air Quality

Technical Support Document (TSD) for a Significant Source Modification and a 

Significant Permit Modification for a Part 70 Operating Permit 

Source Background and Description 

 Source Name: Lehigh Cement Company 

 Source Location: 121 North First Street, P.O. Box 97, 

Mitchell, Indiana 47446 

 County: Lawrence 

SIC Code: 3241 

 Operation Permit No.: T093-5990-00002 

Operation Permit Issuance Date: December 30, 2002 

Significant Source Modification No.: 093-21793-00002 

Significant Permit Modification No.: 093-21975-00002 

 Permit Reviewer: Walter Habeeb

History

On September 13, 2005, Lehigh Cement Company submitted an application to the OAQ 

requesting to add the ability to burn treated wood in Kiln # 1 and Kiln # 2 and to use an existing 

alternate fuel storage and conveyor delivery system for Kiln #1(F19) and an alternate fuel 

storage and conveyor delivery system for Kiln #2 (F20). Lehigh Cement Company was issued 

a Part 70 permit on December 30, 2002. The source has since received the following 

approvals. 

a) Second Administrative Amendment 093-21136-00002, issued April 26, 2005. 

 b) First Administrative Amendment 093-20912-00002, issued April 8, 2005. 

 c) First Exemption 093-20115-00002, issued March 11, 2005. 

 d) Second Significant Source Modification 093-19158-00002, issued November 5, 2004. 

 e) Second Significant Permit Modification 093-18649-00002, issued November 5, 2004. 

 f) First Significant Permit Modification 093-16851-00002, issued July 11, 2003. 

 g) First Significant Source Modification 093-15822-00002, issued June 24, 2003. 

Enforcement Issue

 There are no pending enforcement actions related to this modification. 

Recommendation

 

The staff recommends to the Commissioner that the Part 70 Significant Source Modification 

and Significant Permit Modification be approved. This recommendation is based on the 

following facts and conditions: 

Unless otherwise stated, information used in this review was derived from the application and 

additional information submitted by the applicant. 

 Applications for the purposes of this review were received on September 13, 2005. 
Lehigh Portland Cement Company Page 2 of 30 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Emission Calculations

 

See Appendix A of this document for detailed emissions calculations. 

Potential To Emit of Modification

Pursuant to 326 IAC 2-1.1-1(16), Potential to Emit is defined as “the maximum capacity of a 

stationary source to emit any air pollutant under its physical and operational design. Any 

physical or operational limitation on the capacity of a source to emit an air pollutant, including 

air pollution control equipment and restrictions on hours of operation or type or amount of 

material combusted, stored, or processed shall be treated as part of its design if the limitation is 

enforceable by the U. S. EPA.” 

This table reflects the PTE of Kiln #1 and Kiln #2 alternative fuel delivery systems before 

controls. Control equipment is not considered federally enforceable until it has been required in 

a federally enforceable permit. 

 

Pollutant Potential To Emit (tons/yr) 

PM 0.00 

PM-10 0.00 

SO2 0.00 

VOC 0.00 

CO 0.00 

NOx 0.00 

HAPs 0.00 

 

Justification for Modification 

The Part 70 Operating permit is being modified through a Part 70 Significant Source Modification and a 

Significant Permit Modification. Lehigh is requesting that the modification be processed as a significant 

modification, even though the attached estimated emissions indicate that the treated wood modification 

falls below the 10 tons per year of single HAP threshold and 25 tons per year of any combination HAPs 

threshold because there are no U.S. EPA AP-42 emission factors for kilns while utilizing a blended fuel 

of coal and treated wood. The estimated potential to emit HAP emissions from Kilns #1 and #2 are 

based on U.S. EPA AP-42 HAP emission factors for preheater kilns while utilizing 100% coal. 

County Attainment Status

 The source is located in Lawrence County. 

 

Pollutant Status 

 PM 10 Attainment 

 PM 2.5 Attainment 

SO2 Attainment 

NOx Attainment 

1 Hour Ozone Attainment 

8 Hour Ozone Attainment 

CO Attainment 

Lead Attainment 

 

 (a) Volatile organic compounds (VOC) and oxides of nitrogen (NOx) are precursors for the 

formation of ozone. Therefore, VOC and NOX emissions are considered when 

evaluating the rule applicability relating to the ozone standards. Lawrence County has 

been designated as attainment or unclassifiable for ozone. Therefore, VOC and NOx 
Lehigh Portland Cement Company Page 3 of 30 

Mitchell, Indiana SSM 093-21793-00002

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

 

 emissions were reviewed pursuant to the requirements for Prevention of Significant 

Deterioration (PSD), 326 IAC 2-2. 

(b) Lawrence County has been classified as attainment or unclassifiable for all other 

criteria pollutants. Therefore, these emissions were reviewed pursuant to the 

requirements for Prevention of Significant Deterioration (PSD), 326 IAC 2-2. 

 

 (c) Fugitive Emissions 

Since this type of operation is one of the 28 listed source categories under 326 IAC 2-2, 

the fugitive PM emissions are counted toward determination of PSD and Emission 

Offset applicability. 

Source Status 

Existing Source PSD or Emission Offset Definition (emissions after controls, based upon 8760 

hours of operation per year at rated capacity and/or as otherwise limited): 

 

 Pollutant Emissions (tons/year)

PM greater than 100

PM-10 greater than 100

SO2 greater than 100

VOC less than 100

CO greater than 100 

NOx greater than 100

(a) This existing source is a major stationary source under PSD (326 IAC 2-2), because an 

 attainment regulated pollutant is emitted at a rate of 100 tons per year or more, and it is one 

 of the 28 listed source categories. 

 (b) These emissions are based upon the Title V TSD calculations. 

Potential to Emit of Modification After Issuance

The table below summarizes the potential to emit, reflecting all limits, of the significant 

emission units after controls. The control equipment is considered federally enforceable only 

after issuance of this Part 70 source modification. 

 Potential to Emit (TPY) * 

Process/facility PM PM-10 SO2 VOC CO NOX Pb HAPs 

Potential to 

Emit before 

Modification 

 91.18 190.41 2,417.28 96.56 537.53 3,585.69 0.54397 18.32 

Potential to 

Emit after 

Modification 

 91.18 190.41 2,417.28 96.56 537.53 3,585.69 0.54396 18.32 

Net Emission 

Increase 

 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

• Emissions provided by the source. Before modification emissions based on Part 70 

Operating Permit limits. After modification (alternative fuel delivery system) emissions based 

on AP-42 Section 13.2.4. 
Lehigh Cement Company Page 4 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

 NSR Project Evaluation (tpy) * 

Process/facility PM PM-10 SO2 VOC CO NOX Pb HAPs

Baseline 

Actual 

Emissions 

 66.33 139.76 1,778.93 63.96 395.59 2,638.79 0.01671 13.20 

Projected 

Actual 

Emissions 

 55.78 74.53 1,340.61 9.66 486.03 1,482.23 0.02253 17.78 

Net Emission -10.55 -65.23 -438.32 -54.30 90.44 -1,156.56 0.00582 4.58 

PSD 

Threshold 

Level 

 25 15 40 40 100 40 0.60 10 

Single 

25 All 

• Emissions provided by the source and based on baseline actual emissions for CO, NOx, 

SO2, VOC, PM, PM10 for the time period of April 1998 through March 2000. Baseline actual 

emissions for Pb are based on the time period of August 2003 through July 2005. Baseline 

actual emissions for HAPs are based on the time period of July 2003 through June 2005 

using U.S. EPA AP-42 emission factors for preheater kilns. 

The Permittee has provided information as part of the application for this approval that based on Actual to 

Projected Actual test in 326 IAC 2-2-2 this modification at a major stationary source will not be major for 

Prevention of Significant Deterioration under 326 IAC 2-2-1. IDEM, OAQ has not reviewed this

information and will not be making any determination in this regard as part of this approval. However, in a 

November 29, 2005 letter to the IDEM, Lehigh Cement Company requested this NSR project be 

processed as a significant source modification. IDEM will process this modification as a significant permit 

modification and a significant source modification. 

 

Federal Rule Applicability

(a) The provisions of 40 CFR Part 63, Subpart A - General Provisions, which are incorporated by

 reference in 326 IAC 20-1, apply to the material storage hopper, and each conveyor transfer 

 point associated with the Kiln #1 and Kiln #2 alternative fuel delivery systems (F19 and F20) 

 described in this section except when otherwise specified in 40 CFR Part 63, Subpart LLL. 

(b) Pursuant to 40 CFR 63.1340 (b)(6 & 7) Subpart LLL, (Applicability and Designation of Affected 

 Sources), each material transfer point is subject to the rules of this section. 

(c) Pursuant to 40 CFR 63.1348 Subpart LLL, (Emissions Standards and Operating Limits), the 

visible emissions from each conveyor transfer point associated with the Kiln #1 and Kiln #2 

alternative fuel delivery systems (F19 and F20) shall each not exceed ten percent (10%) opacity. 

State Rule Applicability - Individual Facilities 

326 IAC 2-4.1-1 (New Source Toxic Control) 

The potential to emit HAPs from this modification is less than ten (10) tons per year for a single 

 HAP and less than twenty-five (25) tons per year for any combination of HAP’s. Therefore, the 

 requirements of 326 IAC 2-4.1-1(New Source Toxic Control) are not applicable to this 

 modification. 
Lehigh Cement Company Page 5 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

326 IAC 2-6 (Emission Reporting) 

This source is subject to 326 IAC 2-6 (Emission Reporting), because it has the potential to emit 

more than one hundred (100) tons per year of VOC. Pursuant to this rule, the owner/operator of 

the source must annually submit an emission statement for the source. The annual statement 

must be received by July 1 of each year and contain the minimum requirement as specified in 

326 IAC 2-6-4. The submittal should cover the period defined in 326 IAC 2-6-2(8) (Emission 

Statement Operating Year). 

326 IAC 4-1 (Open Burning) 

The Permittee shall not open burn any material except as provided in 326 IAC 4-1-3, 326 IAC 4-

1-4 or 326 IAC 4-1-6. The previous sentence notwithstanding, the Permittee may open burn in 

accordance with an open burning approval issued by the Commissioner under 326 IAC 4-1-4.1. 

326 IAC 5-1 (Opacity Limitations) 

Pursuant to 326 IAC 5-1-2 (Opacity Limitations), except as provided in 326 IAC 5-1-3 (Temporary 

Exemptions), opacity shall meet the following, unless otherwise stated in the permit: 

(a) Opacity shall not exceed an average of forty percent (40%) in any one (1) six (6) minute 

averaging period as determined in 326 IAC 5-1-4. 

(b) Opacity shall not exceed sixty percent (60%) for more than a cumulative total of fifteen 

(15) minutes (sixty (60) readings as measured according to 40 CFR 60, Appendix A, 

Method 9 or fifteen (15) one (1) minute nonoverlapping integrated averages for a 

continuous opacity monitor) in a six (6) hour period. 

326 IAC 6-3-2 (Particulate Emission Limitations for Manufacturing Processes) 

Pursuant to 326 IAC 6-3-2 (Particulate), the particulate matter (PM) from the material storage 

hopper, and each conveyor transfer point associated with the Kiln #1 and Kiln #2 alternative fuel 

delivery systems (F19 and F20), shall be limited by the following: 

Interpolation of the data for the process weight rate up to sixty thousand (60,000) pounds per 

hour shall be accomplished by use of the equation: 

 E = 4.10 P 0.67 where E = rate of emission in pounds per hour and 

 P = process weight rate in tons per hour 

Compliance Requirements 

Permits issued under 326 IAC 2-7 are required to ensure that sources can demonstrate 

compliance with applicable state and federal rules on a more or less continuous basis. All state 

and federal rules contain compliance provisions, however, these provisions do not always fulfill 

the requirement for a more or less continuous demonstration. When this occurs IDEM, OAQ, in 

conjunction with the source, must develop specific conditions to satisfy 326 IAC 2-7-5. As a 

result, compliance requirements are divided into two sections: Compliance Determination 

Requirements and Compliance Monitoring Requirements. 

 

Compliance Determination Requirements in Section D of the permit are those conditions that are 

found more or less directly within state and federal rules and the violation of which serves as 

grounds for enforcement action. If these conditions are not sufficient to demonstrate continuous 

compliance, they will be supplemented with Compliance Monitoring Requirements, also Section D 

of the permit. Unlike Compliance Determination Requirements, failure to meet Compliance 
Lehigh Cement Company Page 6 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Monitoring conditions would serve as a trigger for corrective actions and not grounds for 

enforcement action. However, a violation in relation to a compliance monitoring condition will 

arise through a source’s failure to take the appropriate corrective actions within a specific time 

period. 

 Pursuant to 40 CFR 63.1350 (Monitoring Requirements), the Permittee shall prepare a written 

operations and maintenance plan for the material storage hoppers and for the conveyor transfer 

points associated with the Kiln #1 alternate fuel delivery system (F19) and the conveyor transfer 

points associated with the Kiln #2 alternate fuel delivery system (F20), upon startup of operations. 

Part 70 Permit Changes 

(1) Section A.2 of the Part 70 Operating Permit 093-5990-00002, issued on December 30, 2002 has 

been revised to include the ability to burn treated wood in Kiln #1 and Kiln #2 and the addition of 

treated wood to the alternative fuel delivery systems (any changes are shown in bold or strikeout

fonts for emphasis): 

 

The raw material handling and storage facilities/emissions units, as follows: 

 (p) A conveying system to transport raw material to storage, identified as EU09, 

constructed in 1960, with a nominal rate of 200 tons per hour, with PM emissions 

controlled by one (1) baghouse, identified as RMDC1, and exhausting to one (1) 

stack, identified as S-RMDC1. 

 (q) One (1) shale crusher, identified as EU10, constructed in 1961, with a nominal 

rate of 200 tons per hour, with PM emissions controlled by one (1) baghouse, 

identified as RMDC2, and exhausting to one (1) stack, identified as S-RMDC2. 

 (r) One (1) material storage building, identified as F03, constructed in 1959-1960, 

with fugitive emissions from various conveyors and storage piles controlled by 

partial enclosure and exhausting directly to the atmosphere. 

 (s) One (1) coal unloading building, identified as F08, constructed in 1960, with 

particulate matter emissions controlled by partial enclosure and exhausting 

directly to the atmosphere. 

 (t) One (1) coal pile, identified as F04, storage commencing prior to 1971, with 

particulate matter emissions uncontrolled, and exhausting directly to the 

atmosphere. 

 (u) Raw material stockpiles collectively, identified as F09, storage commencing prior 

to 1971, used for temporary storage of various feed materials, including gypsum, 

foundry sand, mill scale, and slag, with particulate matter emissions uncontrolled, 

and exhausting to the atmosphere. 

Kiln #1 and Kiln #2 Alternative Fuel Delivery Systems as follows: 

 

 (u.1) One (1) alternative fuel delivery system to convey clean or treated wood fuel to 

Kiln #1, identified as F-19, consisting of a partially enclosed hopper exhausting to 

the atmosphere and a series of totally enclosed conveyors, with a nominal 

throughput of 87,600 tons per year. 

 
Lehigh Cement Company Page 7 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

 (u.2) One (1) alternative fuel delivery system to convey clean or treated wood fuel to 

Kiln #2, identified as F-20, consisting of a partially enclosed hopper exhausting to 

the atmosphere and a series of totally enclosed conveyors, with a nominal 

throughput of 87,600 tons per year. 

 

The kiln facilities/emissions units, as follows: 

 (ccc) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and 

modified to a one-stage preheater kiln in July 2003, with a heat input rate of 118 

million Btu per hour, with a nominal production rate of 38 tons per hour, with PM 

emissions controlled by one (1) electrostatic precipitator (ESP), identified as KP1, 

and dioxins/ furans controlled and SO2 partially controlled by a Water Spray 

Tower, and exhausting to one (1) stack, identified as S-KP1. Kiln #1 is also 

permitted to use a blended fuel of coal and pressed paper making waste where 

the blend has a maximum of 20% pressed paper making waste by heat input. 

 Kiln #1 is permitted to use a blended fuel of coal and clean or treated wood 

where the blend has a maximum of up to 35% clean and/or treated wood by 

heat input. 

 (ddd) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and 

modified to a one-stage preheater kiln in July 2003, with a heat input rate of 118 

million Btu per hour, with a nominal production rate of 38 tons per hour, with PM 

emissions controlled by one (1) electrostatic precipitator (ESP), identified as KP2, 

and dioxins/ furans controlled and SO2 partially controlled by a Water Spray 

Tower, and exhausting to one (1) stack, identified as S-KP1. Kiln #2 is also 

permitted to use a blended fuel of coal and pressed paper making waste where 

the blend has a maximum of 20% pressed paper making waste by heat input. 

 Kiln #2 is permitted to use a blended fuel of coal and clean or treated wood

where the blend has a maximum of up to 35% clean and/or treated wood by 

heat input. 

 (eee) One (1) kiln #3, identified as EU17, constructed in 1974 as a one-stage preheater 

kiln, with a heat input rate of 118 million Btu per hour, with a nominal production 

rate of 43 tons per hour, with PM emissions controlled by one (1) electrostatic 

precipitator (ESP), identified as KP3, and exhausting to one (1) stack, identified 

as S-KP2. Kiln #3 is also permitted to use a blended fuel of coal and pressed 

paper making waste where the blend has a maximum of 20% pressed paper 

making waste by heat input. 

(2) Section D.2 of the Part 70 Operating Permit 093-5990-00002, issued on December 30, 2002 has 

been revised to incorporate the Kiln #1 and Kiln #2 alternative fuel delivery systems (any changes 

are shown in bold or strikeout fonts for emphasis): 
Lehigh Cement Company Page 8 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

SECTION D.2 FACILITY/EMISSION UNIT OPERATION CONDITIONS 

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The raw material handling and storage facilities/emissions units, as follows: 

(1) A conveying system to transport raw material to storage, identified as EU09, constructed in 

1960, with a nominal rate of 200 tons per hour, with PM emissions controlled by one (1) 

baghouse, identified as RMDC1 and exhausting to one (1) stack, identified as S-RMDC1. 

(2) One (1) shale crusher, identified as EU10, constructed in 1961, with a nominal rate of 200 tons 

per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC2, and 

exhausting to one (1) stack, identified as S-RMDC2. 

(3) One (1) material storage building, identified as F03, constructed in 1959-1960, with fugitive 

emissions from various conveyors and storage piles controlled by partial enclosure and 

exhausting directly to the atmosphere. 

(4) One (1) coal unloading building, identified as F08, constructed in 1960, with particulate matter 

emissions controlled by partial enclosure and exhausting directly to the atmosphere. 

(5) One (1) coal pile, identified as F04, constructed prior to 1971, with particulate matter emissions 

uncontrolled, and exhausting directly to the atmosphere. 

(6) Raw material stockpiles collectively, identified as F09, storage commencing prior to 1971, used 

for temporary storage of various feed materials, including gypsum, foundry sand, mill scale, 

and slag, with particulate matter emissions uncontrolled, and exhausting to the atmosphere. 

Kiln #1 and Kiln #2 Alternative Fuel Delivery Systems, as follows: 

 

(1) One (1) alternative fuel delivery system to convey clean or treated wood fuel to Kiln #1, 

identified as F-19, consisting of a partially enclosed hopper exhausting to the atmosphere and 

a series of totally enclosed conveyors, with a nominal throughput of 87,600 tons per year. 

 

(2) One (1) alternative fuel delivery system to convey clean or treated wood fuel to Kiln #2, 

identified as F-20, consisting of a partially enclosed hopper exhausting to the atmosphere and 

a series of totally enclosed conveyors, with a nominal throughput of 87,600 tons per year. 

The raw mill facilities/emissions units, as follows: 

(1) One (1) raw mill #1, identified as EU11, constructed in 1961, with a nominal rate of 100 tons 

per hour and including a natural gas-fired burner, identified as EU11A, with a maximum heat 

input capacity of 20 million British thermal units (MMBtu) per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC3, and exhausting to one (1) stack, identified 

as S-RMDC3. 

(2) One (1) raw mill #2, identified as EU12, constructed in 1961, with a nominal rate of 100 tons 

per hour and including a natural gas-fired burner, identified as EU12A, with a maximum heat 

input capacity of 20 million British thermal units (MMBtu) per hour, with PM emissions controlled by one (1) baghouse, identified as RMDC4, and exhausting to one (1) stack, identified 
Lehigh Cement Company Page 9 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

as S-RMDC4. 

Insignificant Activities, as follows: 

(1) Three (3) coal mills, with nominal rates of 5, 6, and 6 tons per hour, with particulate matter 

emissions controlled by total enclosure, and exhausting to the kilns. 

(2) One coal feeder conveyor and one coal unloading conveyor, with nominal rates of 250 tons per 

hour and 260 tons per hour, respectively, constructed prior to August 17, 1971, with particulate 

matter emissions controlled by total enclosure. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

(3) Section D.4 of the Part 70 Operating Permit 093-5990-00002, issued on December 30, 2002 has 

been revised to incorporate the Kiln #1 and Kiln #2 alternate fuel delivery systems (any changes 

are shown in bold or strikeout fonts for emphasis): 

SECTION D.4 FACILITY/EMISSION UNIT OPERATION CONDITIONS

Facility/Emissions Unit Description [326 IAC 2-7-5(15)] 

The kiln facilities/emissions units, as follows: 

(1) One (1) kiln #1, identified as EU15, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a 

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP1, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #1 is also permitted to use a blended fuel of coal and pressed paper making waste 

where the blend has a maximum of 20% pressed paper making waste by heat input. 

Kiln #1 is permitted to use a blended fuel of coal and clean or treated wood where the blend 

has a maximum of up to 35% clean and/or treated wood by heat input. 

 

(2) One (1) kiln #2, identified as EU16, constructed in 1959 as a long dry kiln and modified to a 

one-stage preheater kiln in July 2003, with a heat input rate of 118 million Btu per hour, with a 

nominal production rate of 38 tons per hour, with PM emissions controlled by one (1) 

electrostatic precipitator (ESP), identified as KP2, and dioxins/furans controlled and SO2

partially controlled by a Water Spray Tower, and exhausting to one (1) stack, identified as SKP1. Kiln #2 is also permitted to use a blended fuel of coal and pressed paper making waste 

where the blend has a maximum of 20% pressed paper making waste by heat input. 

Kiln #2 is permitted to use a blended fuel of coal and clean or treated wood where the blend 

has a maximum of up to 35% clean and/or treated wood by heat input. 

(3) One (1) kiln #3, identified as EU17, constructed in 1974 as a one-stage preheater kiln, with a 

heat input rate of 118 million Btu per hour, with a nominal production rate of 43 tons per hour, 

with PM emissions controlled by one (1) electrostatic precipitator (ESP), identified as KP3, and 

exhausting to one (1) stack, identified as S-KP2. Kiln #3 is also permitted to use a blended 

fuel of coal and pressed paper making waste where the blend has a maximum of 20% pressed 
Lehigh Cement Company Page 10 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

paper making waste by heat input. 

(The information describing the processes contained in this facility description box is descriptive 

information and does not constitute enforceable conditions.) 

Emission Limitations and Standards [326 IAC 2-7-5(1)] 

D.4.1.1 Kiln #1 and Kiln #2 Partial Fuel Switch, Applicability [326 IAC 2-2-2(d)] 

Pursuant to 326 IAC 2-2-2(d), Kiln #1 and Kiln #2 are permitted to burn a blended fuel of 

coal and clean or treated wood where the blend has a maximum of up to 35% clean 

and/or treated wood by heat input. 

The changes listed below have been made to the Part 70 Operation Permit No. 093-5990-00002. 

Deleted language appears as strikethroughs and new language appears in bold: 

Change No. 1: 

IDEM has determined that the Permittee is not required to keep records of all preventive 

maintenance. However, where the Permittee seeks to demonstrate that an emergency has occurred, 

the Permittee must provide, upon request, records of preventive maintenance in order to establish 

that the lack of proper maintenance did not cause or contribute to the deviation. Therefore, IDEM has 

deleted paragraph (b) of Section B – Preventive Maintenance, and has amended the Section B – 

Emergency Provisions condition as follows: 

B.11 Preventive Maintenance Plan [326 IAC 2-7-5(1),(3) and (13)] [326 IAC 2-7-6(1) and (6)] [326 IAC 

1-6-3] 

(a) If required by specific condition(s) in Section D of this permit, the Permittee shall prepare 

and maintain Preventive Maintenance Plans (PMP) within ninety (90) days after issuance 

of this permit, including the following information on each facility/emissions unit: 

(1) Identification of the individual(s) responsible for inspecting, maintaining, and 

repairing emission control devices; 

(2) A description of the items or conditions that will be inspected and the inspection 

schedule for said items or conditions; 

(3) Identification and quantification of the replacement parts that will be maintained 

in inventory for quick replacement. 

If due to circumstances beyond the Permittee’s control, the PMP cannot be prepared and 

maintained within the above time frame, the Permittee may extend the date an additional 

ninety (90) days provided the Permittee notifies:

Indiana Department of Environmental Management

Compliance Branch, Office of Air Quality

100 North Senate Avenue, 

Indianapolis, Indiana 46204

The PMP and the PMP extension notification do not require the certification by the 

“responsible official” as defined by 326 IAC 2-7-1(34). 
Lehigh Cement Company Page 11 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(b) The Permittee shall implement the PMPs, including any required record keeping, as 

necessary to ensure that failure to implement a PMP does not cause or contribute to an 

exceedance of any limitation on emissions or potential to emit. 

(c) A copy of the PMPs shall be submitted to IDEM, OAQ, upon request and within a 

reasonable time, and shall be subject to review and approval by IDEM, OAQ. IDEM, 

OAQ may require the Permittee to revise its PMPs whenever lack of proper maintenance 

causes or is the primary contributor to an exceedance of any limitation on emissions or 

potential to emit. The PMPs does not require the certification by the “responsible official” 

as defined by 326 IAC 2-7-1(34). 

(d) To the extent the Permittee is required by 40 CFR Part 60/63 to have an Operation, 

Maintenance, and Monitoring (OMM) Plan for a unit, such Plan is deemed to satisfy the 

PMP requirements of 326 IAC 1-6-3 for that unit. 

B.12 Emergency Provisions [326 IAC 2-7-16]

(a), (b) and (c) remain the same 

(d) This emergency provision supersedes the malfunction rule, 326 IAC 1-6 (Malfunctions). 

(except the requirement for a PMP in 326 IAC 1-6-3), for sources subject to 326 IAC 2-7

after the effective date of 326 IAC 2-7. This permit condition is in addition to any 

emergency or upset provision contained in any applicable requirement. 

(e) The Permittee shall make records available upon request to ensure that failure to 

implement a PMP did not cause or contribute to an exceedance of any limitations 

on emissions. However, IDEM, OAQ, may require that the Preventive Maintenance 

Plans required under 326 IAC 2-7-4(c)(9) be revised in response to an emergency. 

(f) Failure to notify IDEM, OAQ, by telephone, facsimile, or other agreed upon method, of an 

emergency lasting more than one (1) hour in accordance with (b)(4) and (5) of this 

condition shall constitute a violation of 326 IAC 2-7 and any other applicable rules. 

(g) If the emergency situation causes a deviation from a technology-based limit, the 

Permittee may continue to operate the affected emitting facilities/emissions units during 

the emergency provided the Permittee immediately takes all reasonable steps to correct 

the emergency and minimize emissions. 

 

(h) The Permittee shall include all emergencies in the Quarterly Deviation and 

Compliance Monitoring Report. 

B.20 Operational Flexibility [326 IAC 2-7-20] [326 IAC 2-7-10.5]

(a) The Permittee may make any change or changes at the source that are described in 326 

IAC 2-7-20(b), (c), or (e), without a prior permit revision, if each of the following conditions 

is met: 

(1) The changes are not modifications under any provision of Title I of the Clean Air 

Act; 

(2) Any preconstruction approval required by 326 IAC 2-7-10.5 has been obtained; 
Lehigh Cement Company Page 12 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(3) The changes do not result in emissions which exceed the emissions allowable 

under this permit (whether expressed herein as a rate of emissions or in terms of 

total emissions); 

(4) The Permittee notifies the: 

Indiana Department of Environmental Management 

Permits Branch, Office of Air Quality 

100 North Senate Avenue, P.O. Box 6015

Indianapolis, Indiana 46206-6015 46204-2251

 

and 

United States Environmental Protection Agency, Region V 

Air and Radiation Division, Regulation Development Branch - Indiana (AR-18J) 

77 West Jackson Boulevard 

Chicago, Illinois 60604-3590 

in advance of the change by written notification at least ten (10) days in advance 

of the proposed change. The Permittee shall attach every such notice to the 

Permittee's copy of this permit; and 

(5) The Permittee maintains records on-site, on a rolling five (5) year basis, which 

document, on a rolling five (5) year basis, all such changes and emissions 

trading trades that are subject to 326 IAC 2-7-20(b), (c), or (e). and makes The 

Permittee shall make such records available, upon reasonable request, for 

public review. 

Such records shall consist of all information required to be submitted to IDEM, 

OAQ, in the notices specified in 326 IAC 2-7-20(b)(1), (c)(1), and (e)(2). 

(b) remains the same 

(c) Emission Trades [326 IAC 2-7-20(c)] 

The Permittee may trade emissions increases and decreases in emissions in at the 

source, where the applicable SIP provides for such emission trades without requiring a 

permit revision, subject to the constraints of Section (a) of this condition and those in 326 

IAC 2-7-20(c). 

(d) remains the same 

Change No. 2: 

Indiana was required to incorporate credible evidence provisions into state rules 

consistent with the SIP call published by U.S. EPA in 1997 (62 FR 8314). Indiana has 

incorporated the credible evidence provision in 326 IAC 1-1-6. This rule is effective 

March 16, 2005; therefore, the condition reflecting this rule will be incorporated into your 

permit as follows: 

B.25 Credible Evidence [326 IAC 2-7-5(3)][326 IAC 2-7-6][62 FR 8314] [326 IAC 1-16] 

Notwithstanding the conditions of this permit that state specific methods that may be used to 

demonstrate compliance with, or a violation of, applicable requirements, any person (including the
Lehigh Cement Company Page 13 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Permittee) may also use other credible evidence to demonstrate compliance with, or a violation 

of, any term or condition of this permit.

For the purpose of submitting compliance certifications or establishing whether or not the 

Permittee has violated or is in violation of any condition of this permit, nothing in this 

permit shall preclude the use, including the exclusive use, of any credible evidence or 

information relevant to whether the Permittee would have been in compliance with the 

condition of this permit if the appropriate performance or compliance test procedure had 

been performed. 

Change No.3: 

COM Downtime 

Upon further review, IDEM has determined that no additional monitoring will be required during 

COM downtime, until the COM has been down for twenty-four (24) hours. This allows the 

Permittee to focus on the task of repairing the COM during the first twenty-four (24) hour period. 

After twenty-four (24) hours of COM downtime, the Permittee will be required to conduct Method 

9 readings for thirty (30) minutes. Once Method 9 readings are required to be performed, the 

readings should be performed twice per day at least 4 or 6 hours apart, rather than once every 

four (4) hours, until a COMS is back in service. 

 

C.12 Maintenance of Continuous Opacity Monitoring Equipment [326 IAC 2-7-5(3)(A)(iii)] 

(a) The Permittee shall install, calibrate, maintain, and operate all necessary continuous 

opacity monitoring systems (COMS) and related equipment. For a boiler, the COMS

shall be in operation at all times that the induced draft fan is in operation. 

(b) All continuous opacity monitoring systems COMS shall meet the performance 

specifications of 40 CFR 60, Appendix B, Performance Specification No. 1, and are 

subject to monitor system certification requirements pursuant to 326 IAC 3-5. 

(c) In the event that a breakdown of a continuous opacity monitoring system COMS occurs, 

a record shall be made of the times and reasons of the breakdown and efforts made to 

correct the problem. 

(A)(d) Whenever a continuous opacity monitor (COM) COMS is malfunctioning or will be is 

down for calibration, maintenance or repairs for a period of one (1) hour twenty-four (24) 

hours or more and a backup COMS is not online within twenty-four (24) hours of

shutdown or malfunction of the primary COMS, compliance with the applicable

opacity limits shall be demonstrated by the following:

(1) Visible emission (VE) notations shall be performed once per hour during daylight 

operations following the shutdown or malfunction of the primary COM. A trained 

employee shall record whether emissions are normal or abnormal for the state of 

operation of the emission unit at the time of the reading.

(A) A trained employee is an employee who has worked at the plant at least 

one (1) month and has been trained in the appearance and 

characteristics of normal visible emissions for that specific process.

(B) If abnormal emissions are noted during two consecutive emission 

notations, the Permittee shall begin Method 9 opacity observations within 

four hours of the second abnormal notation.
Lehigh Cement Company Page 14 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(C) VE notations may be discontinued once a COM is online or formal 

Method 9 readings have been implemented.

(2) If a COM is not online within twenty-four (24) hours of shutdown or malfunction of 

the primary COM, the Permittee shall provide a certified opacity reader(s), who 

may be an employees of the Permittee or an independent contractors, to selfmonitor the emissions from the emission unit stack. 

(A) (1) Visible emission readings shall be performed in accordance with 40 CFR 60, 

Appendix A, Method 9, for a minimum of five (5) consecutive six (6) minute 

averaging periods beginning not more than twenty-four (24) hours after the start 

of the malfunction or down time. 

(B) (2) Method 9 opacity readings shall be repeated for a minimum of five (5) 

consecutive six (6) minute averaging periods at least once every four (4) hours

twice per day during daylight operations, with at least four (4) hours between

each set of readings, until such time that a COMS is in operation online. 

(C) (3) Method 9 readings may be discontinued once a COMS is online. 

(D) (4) Any opacity exceedances determined by Method 9 readings shall be reported 

with the Quarterly Opacity Exceedances Reports. 

(E) If abnormal emissions are observed, the Permittee shall take reasonable 

response steps in accordance with Section C - Compliance Response Plan -

Preparation, Implementation, Records, and Reports. Observation of abnormal 

emissions that do not violate an applicable opacity limit is not a deviation from 

this permit. Failure to take response steps in accordance with Section C -

Compliance Response Plan - Preparation, Implementation, Records, and 

Reports, shall be considered a deviation from this permit.

 (e) Nothing in this permit shall excuse the Permittee from complying with the requirements to 

operate a continuous opacity monitoring system pursuant to 326 IAC 3-5, 40 CFR 63, 

Subpart LLL. 

Change No. 4: 

IDEM realizes that these specifications can only be practically applied to analog units, and has 

therefore clarified the condition to state that the condition only applies to analog units. Upon further 

review, IDEM has also determined that the accuracy of the instruments is not nearly as important as 

whether the instrument has a range that is appropriate for the normal expected reading of the 

parameter. Therefore, the accuracy requirements have been removed from the condition. 

C.14 Pressure Gauge and Other Instrument Specifications [326 IAC 2-1.1-11] [326 IAC 2-7-5(3)] [326 

IAC 2-7-6(1)] 

(a) Whenever a condition in this permit requires the measurement of pressure drop across 

any part of the unit or its control device, the gauge employed When required by any 

condition of this permit, an analog instrument used to measure a parameter related 

to the operation of an air pollution control device shall have a scale such that the 

expected normal maximum reading for the normal range shall be no less than twenty 
Lehigh Cement Company Page 15 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

percent (20%) of full scale and be accurate within plus or minus two percent (2%) of full 

scale reading. 

(b) Whenever a condition in this permit requires the measurement of a (temperature or flow 

rate), the instrument employed shall have a scale such that the expected normal reading 

shall be no less than twenty percent (20%) of full scale and be accurate within plus or 

minus two percent (2%) of full scale reading. 

(c) The Preventive Maintenance Plan for the pH meter shall include calibration using known 

standards. The frequency of calibration shall be adjusted such that the typical error 

found at calibration is less than one pH point.

(d b) The Permittee may request that the IDEM, OAQ approve the use of a pressure gauge or 

other an instrument that does not meet the above specifications provided the Permittee 

can demonstrate that an alternative pressure gauge or other instrument specification will 

adequately ensure compliance with permit conditions requiring the measurement of 

pressure drop or other the parameters. 

Change No. 5: 

IDEM has reconsidered the requirement to develop and follow a Compliance Response Plan. The 

Permittee will still be required to take reasonable response steps when a compliance monitoring 

parameter is determined to be out of range or abnormal. Replacing the requirement to develop and 

follow a Compliance Response Plan with a requirement to take reasonable response steps will 

ensure that the control equipment is returned to proper operation as soon as practicable, while still 

allowing the Permittee the flexibility to respond to situations that were not anticipated. The Section D 

conditions that refer to this condition have been revised to reflect the new condition title, and the 

following changes have been made to the Section C condition: 

C.17 Compliance Response Plan - Preparation, Implementation, Records, and Reports Response to 

Excursions or Exceedances [326 IAC 2-7-5] [326 IAC 2-7-6] 

(a) The Permittee is required to prepare a Compliance Response Plan (CRP) for each 

compliance monitoring condition of this permit. If a Permittee is required to have an 

Operation, Maintenance and Monitoring (OMM) Plan (or Parametric Monitoring Plan and 

Start-up, Shutdown, and Malfunction (SSM) Plan) under 40 CFR 60/63, such plans shall 

be deemed to satisfy the requirements for a CRP for those compliance monitoring 

conditions. A CRP shall be submitted to IDEM, OAQ upon request. The CRP shall be 

prepared within ninety (90) days after issuance of this permit by the Permittee, 

supplemented from time to time by the Permittee, maintained on site, and comprised of:

(1) Reasonable response steps that may be implemented in the event that a 

response step is needed pursuant to the requirements of Section D of this permit; 

and an expected timeframe for taking reasonable response steps.

(2) If, at any time, the Permittee takes reasonable response steps that are not set 

forth in the Permittee’s current Compliance Response Plan or Operation, 

Maintenance and Monitoring (OMM) Plan (or Parametric Monitoring Plan and 

Start-up, Shutdown, and Malfunction (SSM) Plan) and the Permittee documents 

such response in accordance with subsection (e) below, the Permittee shall 

amend its Compliance Response Plan or Operation, Maintenance and Monitoring 
Lehigh Cement Company Page 16 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(OMM) Plan (or Parametric Monitoring Plan and Start-up, Shutdown, and 

Malfunction (SSM) Plan) to include such response steps taken. 

 The OMM Plan (or Parametric Monitoring and SSM Plan) shall be submitted within the 

time frames specified by the applicable 40 CFR60/63 requirements.

(b) For each compliance monitoring condition of this permit, reasonable response steps shall 

be taken when indicated by the provisions of that compliance monitoring condition as 

follows:

(1) Reasonable response steps shall be taken as set forth in the Permittee’s current 

Compliance Response Plan or Operation, Maintenance and Monitoring (OMM) 

Plan (or Parametric Monitoring Plan and Start-up, Shutdown, and Malfunction 

(SSM) Plan); or

(2) If none of the reasonable response steps listed in the Compliance Response Plan 

or Operation, Maintenance and Monitoring (OMM) Plan (or Parametric Monitoring 

Plan and Start-up, Shutdown, and Malfunction (SSM) Plan) is applicable or 

responsive to the excursion, the Permittee shall devise and implement additional 

response steps as expeditiously as practical. Taking such additional response 

steps shall not be considered a deviation from this permit so long as the 

Permittee documents such response steps in accordance with this condition.

(3) If the Permittee determines that additional response steps would necessitate that the 

emissions unit or control device be shut down, and it will be ten (10) days or 

more until the unit or device will be shut down, then the Permittee shall promptly 

notify the IDEM, OAQ of the expected date of the shut down. The notification 

shall also include the status of the applicable compliance monitoring parameter 

with respect to normal, and the results of the response actions taken up to the 

time of notification.

(4) Failure to take reasonable response steps shall be considered a deviation from 

the permit.

(c) The Permittee is not required to take any further response steps for any of the following 

reasons:

(1) A false reading occurs due to the malfunction of the monitoring equipment and 

prompt action was taken to correct the monitoring equipment.

(2) The Permittee has determined that the compliance monitoring parameters 

established in the permit conditions are technically inappropriate, has previously 

submitted a request for a minor permit modification to the permit, and such 

request has not been denied.

(3) An automatic measurement was taken when the process was not operating.

(4) The process has already returned or is returning to operating within “normal” 

parameters and no response steps are required.

(d) When implementing reasonable steps in response to a compliance monitoring condition, if 

the Permittee determines that an exceedance of an emission limitation has occurred, the 
Lehigh Cement Company Page 17 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Permittee shall report such deviations pursuant to Section B-Deviations from Permit 

Requirements and Conditions.

(e) The Permittee shall record all instances when, in accordance with Section D, response 

steps are taken. In the event of an emergency, the provisions of 326 IAC 2-7-16 

(Emergency Provisions) requiring prompt corrective action to mitigate emissions shall 

prevail.

(f) Except as otherwise provided by a rule or provided specifically in Section D, all monitoring 

as required in Section D shall be performed when the emission unit is operating, except 

for time necessary to perform quality assurance and maintenance activities.

 

If required by a specific condition in Section D of this permit: 

(a) Upon detecting an excursion or exceedance, the Permittee shall restore operation 

of the emissions unit (including any control device and associated capture system) 

to its normal or usual manner of operation as expeditiously as practicable in 

accordance with good air pollution control practices for minimizing emissions. 

(b) The response shall include minimizing the period of any startup, shutdown or 

malfunction and taking any necessary corrective actions to restore normal 

operation and prevent the likely recurrence of the cause of an excursion or 

exceedance (other than those caused by excused startup or shutdown 

conditions). Corrective actions may include, but are not limited to, the following: 

(1) initial inspection and evaluation; 

(2) recording that operations returned to normal without operator action (such 

as through response by a computerized distribution control system); or 

(3) any necessary follow-up actions to return operation to within the indicator 

range, designated condition, or below the applicable emission limitation or 

standard, as applicable. 

(c) A determination of whether the Permittee has used acceptable procedures in 

response to an excursion or exceedance will be based on information available, 

which may include, but is not limited to, the following: 

(1) monitoring results; 

(2) review of operation and maintenance procedures and records; 

(3) inspection of the control device, associated capture system, and the 

process. 

(d) Failure to take reasonable response steps shall be considered a deviation from the 

permit. 

(e) The Permittee shall maintain the following records: 

(1) monitoring data; 
Lehigh Cement Company Page 18 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(2) monitor performance data, if applicable; and 

(3) corrective actions taken. 

(f) For purposes of this Condition: 

 

(1) “Exceedance” shall mean a condition that is detected by monitoring that 

 provides data in terms of an emission limitation or standard and that

 indicates that emissions are, or opacity is, greater that the applicable

 emission limitation or standard (or less than the applicable standard in the 

 case of a percent reduction requirement), consistent with any averaging 

 period specified for averaging the results of the monitoring. 

(2) “Excursion” shall mean a departure from an indicator range established for 

 monitoring under Section D of this permit, consistent with any averaging 

 period specified for averaging the results of the monitoring. 

Change No. 6: 

Section D Updates 

D.1.4 Preventive Maintenance Plan [326 IAC 2-7-5(13)] 

A Preventive Maintenance Plan, in accordance with Section B - Preventive Maintenance Plan, of 

this permit, is required for this facility and its the control devices listed in this section. 

D.1.5 Particulate Control 326 IAC 2-7-6(6)

(a) Pursuant to minor source modification 093-11313 issued November 9, 1999, for the CKD 

mixer (EU24B), and in order for all units to comply with Conditions D.1.1 and D.1.3, except 

as otherwise provided by statute, rule or this permit, each baghouse listed in this section 

for particulate control shall be in operation and control emissions at all times when its 

associated facility/emissions unit is in operation.

(b) In the event that bag failure is observed in a multi-compartment baghouse, if 

operations will continue for ten (10) days or more after the failure is observed 

before the failed units will be repaired or replaced, the Permittee shall promptly

notify the IDEM, OAQ of the expected date the failed units will be repaired or 

replaced. The notification shall also include the status of the applicable compliance 

monitoring parameters with respect to normal, and the results of any response 

actions taken up to the time of notification. 

D.1.7 Visible Emissions Notations 

Visible emission notations of all the baghouse stack exhausts shall be performed once per shift

day during normal daylight operations. A trained employee shall record whether emissions are

normal or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month
Lehigh Cement Company Page 19 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process. 

(d) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an If abnormal emissions is are observed or when visible

emissions are observed crossing the property line, the Permittee shall take reasonable

response steps in accordance with Section C - Response to Excursions or Exceedances

or when visible emissions are observed crossing the property line. Failure to take

response steps in accordance with Section C - Compliance Response Plan- Preparation,

Implementation, Records, and Reports Response to Excursions or Exceedances shall

be considered a violation deviation of this permit. 

D.1.8 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse listed in this

section, at least once per shift day when the associated facility/emissions unit is in operation.

When for any one reading, the pressure drop across a baghouse is outside the normal range of 

1.0 and 8.0 inches of water or a range established during the latest stack test, the Permittee shall 

take reasonable response steps in accordance with Section C – Compliance Response PlanPreparation, Implementation Records, and Reports Response to Excursions or Exceedances. 

A pressure reading that is outside the above mentioned range is not a deviation from this permit. 

Failure to take response steps in accordance with Section C - Compliance Response PlanPreparation, Implementation Records, and Reports Response to Excursions or Exceedances, 

shall be considered a violation of this permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

Change No. 7 

Upon further review, IDEM has determined that it is the Permittee’s responsibility to include routine

control device inspection requirements in the applicable preventive maintenance plan. Since the

Permittee is in the best position to determine the appropriate frequency of control device inspections and

the details regarding which components of the control device should be inspected, the conditions

requiring control device inspections have been removed from the permit. In addition, the requirement to

keep records of the inspections has been removed. 

D.1.9 Baghouse Inspections

An inspection shall be performed each calendar quarter of all bags controlling the processes

listed in this section when venting to the atmosphere. A baghouse inspection shall be performed 

within three months of redirecting vents to the atmosphere and every three months thereafter. 

Inspections are optional when venting to the indoors. Inspections required by this condition shall 

not be performed in consecutive months. All defective bags shall be replaced. 

D.1.10 9 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the
Lehigh Cement Company Page 20 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 

(b) (a) For a single compartment baghouses controlling emissions from a process operated

continuously, if failure is indicated by a significant drop in the baghouse’s pressure 

readings with abnormal visible emissions or the failure is indicated by an opacity

violation, or if bag failure is determined by other means, such as gas temperatures, flow

rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the associated

process will shall be shut down immediately until the failed units have been repaired or

replaced. Operations may continue only if the event qualifies as an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this permit (Section

B - Emergency Provisions).

(b) For a single compartment baghouses controlling emissions from a batch process, if

failure is indicated by a significant drop in the baghouse’s pressure readings with

abnormal visible emissions or the failure is indicated by an opacity violation, or if bag

failure is determined by other means, such as gas temperatures, flow rates, air infiltration, 

leaks, dust traces, or triboflows, then the feed to the process failed units and the

associated process will shall be shut down immediately until the failed units have been 

repaired or replaced. The emissions unit shall be shut down no later than the

completion of the processing of the material in the line. Operations may continue

only if the event qualifies as an emergency and the Permittee satisfies the requirements 

of the emergency provisions of this permit (Section B - Emergency Provisions).

Bag failure can be indicated by a significant drop in the baghouses pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means such as gas 

temperature, flow rate, air infiltration leaks, dust traces or triboflows. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.1.11 10 Record Keeping Requirements 

(a) To document compliance with Condition D.1.3(b)(1), the Permittee shall maintain records 

of the Primary crusher (EU01), the Surge Bin and Transfer System (EU02), the Secondary Crusher (EU03), the Tertiary Crusher (EU04), the North Screen House (EU05), the 

South Screen House (EU06), the Belt #7 to Belt #8 Conveyor Transfer Point (EU07) and 

the Belt #8 to Belt #9 Conveyor transfer point (EU08) operating hours. 

(b) To document compliance with Condition D.1.7, the Permittee shall maintain records of

visible emission notations of the baghouse stack exhausts once per shift day. 

(c) To document compliance with Condition D.1.8, the Permittee shall maintain records of

the differential static of pressure drop across each baghouse once per shift day. 

(d) To document compliance with Condition D.1.9, the Permittee shall maintain records of

the results of the inspections required under Condition D.1.9.
Lehigh Cement Company Page 21 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(e) (d) All records shall be maintained in accordance with Section C - General Record Keeping

Requirements, of this permit. 

D.1.12 11 Reporting Requirements 

No other changes. 

D.2.10 Particulate Control 326 IAC 2-7-6(6)

(a) Except as otherwise provided by statute, rule or this permit, each the baghouses listed in 

this section for particulate PM control shall be in operation and control emissions at all

times when its associated facility/emissions unit is in operation in order to comply with 

Conditions D.2.1, D.2.3 and D.2.7. 

(b) In the event that bag failure is observed in a multi-compartment baghouse, if 

operations will continue for ten (10) days or more after the failure is observed 

before the failed units will be repaired or replaced, the Permittee shall promptly

notify the IDEM, OAQ of the expected date the failed units will be repaired or 

replaced. The notification shall also include the status of the applicable compliance 

monitoring parameters with respect to normal, and the results of any response 

actions taken up to the time of notification. 

D.2.12 Visible Emissions Notations 

Visible emission notations of all of the baghouse stack exhausts controlling the raw mills (EU11, 

EU11A, EU12 and EU12A), shall be performed once per day during normal daylight operations.

Visible emission notations of all other baghouse stack exhausts shall be performed once per shift

day during normal daylight operations. A trained employee shall record whether emissions from 

the stacks are normal or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process.

(d) On days that the NESHAP monitoring required in Condition D.2.11 is performed, the

Permittee may use those results to satisfy the requirements of this condition for the units 

subject to the NESHAP. 

(e) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an If abnormal emissions is are observed, the Permittee

shall take reasonable response steps in accordance with Section C - Response to

Excursions or Exceedances or when visible emissions are observed crossing the

property line. Failure to take response steps in accordance with Section C - Compliance 

Response Plan- Preparation, Implementation, Records, and Reports Response to

Excursions or Exceedances shall be considered a violation deviation of this permit. 
Lehigh Cement Company Page 22 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

D.2.13 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse controlling the 

raw mills (EU11, EU11A, EU12 and EU12A) at least once per shift day when the associated

facility/ emissions unit is in operation. The Permittee shall record the pressure drop across all

other baghouses listed in this section, at least once per day when the associated facility/ 

emissions unit is in operation. When for any one reading, the pressure drop across each baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range established during

the latest stack test, the Permittee shall take reasonable response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports

Response to Excursions or Exceedances. A pressure reading that is outside the above

mentioned range is not a deviation from this permit. Failure to take response steps in accordance

with Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports Response to Excursions or Exceedances, shall be considered a violation deviation of 

this permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.2.14 Baghouse Inspections

An inspection shall be performed each calendar quarter of all bags controlling the processes

listed in this section when venting to the atmosphere. A baghouse inspection shall be performed 

within three months of redirecting vents to the atmosphere and every three months thereafter. 

Inspections are optional when venting to the indoors. Inspections required by this condition shall 

not be performed in consecutive months. All defective bags shall be replaced. 

D.2.15 14 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the

Compliance Response Plan shall be initiated. For any failure with corresponding

response steps and timetable not described in the Compliance Response Plan, response 

steps shall be devised within eight (8) business hours of discovery of the failure and shall 

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and 

Reports, shall be considered a violation of this permit.

(b) (a) For a single compartment baghouses controlling emissions from a process operated

continuously, if failure is indicated by a significant drop in the baghouse’s pressure 

readings with abnormal visible emissions or the failure is indicated by an opacity

violation, or if bag failure is determined by other means, such as gas temperatures, flow

rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the associated

process will shall be shut down immediately until the failed units have been repaired or

replaced. Operations may continue only if the event qualifies as an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this permit (Section

B - Emergency Provisions).
Lehigh Cement Company Page 23 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(b) For a single compartment baghouses controlling emissions from a batch process, if

failure is indicated by a significant drop in the baghouse’s pressure readings with

abnormal visible emissions or the failure is indicated by an opacity violation, or if bag

failure is determined by other means, such as gas temperatures, flow rates, air infiltration, 

leaks, dust traces, or triboflows, then the feed to the process failed units and the

associated process will shall be shut down immediately until the failed units have been 

repaired or replaced. The emissions unit shall be shut down no later than the

completion of the processing of the material in the line. Operations may continue

only if the event qualifies as an emergency and the Permittee satisfies the requirements 

of the emergency provisions of this permit (Section B - Emergency Provisions).

Bag failure can be indicated by a significant drop in the baghouses pressure reading with

abnormal visible emissions, by an opacity violation, or by other means such as gas

temperature, flow rate, air infiltration, leaks, dust traces or triboflows. 

Record Keeping and Reporting Requirements [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.2.16 15 Record Keeping Requirements 

(a) To document compliance with Condition D.2.12, the Permittee shall maintain records of

visible emission notations of the baghouse stack exhausts controlling the raw mills 

(EU11, EU11A, EU12 and EU12A) once per day and all other baghouse stack exhausts

once per shift day. 

(b) To document compliance with Condition D.2.13, the Permittee shall maintain records of

the differential static pressure drop across of each baghouse controlling the raw mills 

(EU11, EU11A, EU12 and EU12A) once per day and all other baghouses once per shift

day. 

(c) To document compliance with Condition D.2.14, the Permittee shall maintain records of

the results of the inspections required under Condition D.2.14.

(d) (c) On and after the NESHAP 40 CFR 63, Subpart LLL compliance date, to document 

compliance with the NESHAP, the Permittee shall maintain all records required by 40

CFR 63.1355. These records include the following: 

(1) The Permittee shall maintain files of all information (including all reports and

notifications) required by 40 CFR 60.1355(a) recorded in a form suitable and 

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(e) To document compliance with Condition D.2.7(a), the Permittee shall maintain records of

the Conveying System to Transport Raw Material to Storage (EU09) and the Shale 

Crusher (EU10) operating hours. 
Lehigh Cement Company Page 24 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(f) All records shall be maintained in accordance with Section C - General Record Keeping 

Requirements, of this permit. 

D.2.17 16 Reporting Requirements 

No other Changes. 

 

D.3.9 Particulate Control 326 IAC 2-7-6(6)

(a) Pursuant to CP093-2770 issued March 3, 1993, for the three clinker ladders (EU26c, 

EU28 and EU30 and the lime bin (EU38), and in order for all units to comply with 

Conditions D.3.1, D.3.4 and D.3.6, except as otherwise provided by statute, rule or this 

permit, each baghouse listed in this section for particulate control shall be in operation 

and control emissions at all times when its associated facility/emissions unit is in 

operation. 

 (b) In the event that bag failure is observed in a multi-compartment baghouse, if 

operations will continue for ten (10) days or more after the failure is observed 

before the failed units will be repaired or replaced, the Permittee shall promptly 

notify the IDEM, OAQ of the expected date the failed units will be repaired or 

replaced. The notification shall also include the status of the applicable compliance 

monitoring parameters with respect to normal, and the results of any response 

actions taken up to the time of notification. 

D.3.11 Visible Emissions Notations 

Visible emission notations of all of the baghouse stack exhausts controlling the raw mill storage 

facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points 

associated with the clinker handling facilities/emission units (EU25, EU26a, EU26b, EU27, and 

EU29) the roll crusher (EU31), the finish mill facilities/emission units (EU32 through EU36 and 

EU38), and the finish material storage and bulk loading and packaging facilities/emission units 

(EU37, EU39 through EU47) shall be performed once per day during normal daylight operations. 

Visible emission notations of all other baghouse stack exhausts shall be performed once per shift

day during normal daylight operations. A trained employee shall record whether emissions are 

normal or abnormal. 

(a) For processes operated continuously, "normal" means those conditions prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

(b) In the case of batch or discontinuous operations, readings shall be taken during that part 

of the operation that would normally be expected to cause the greatest emissions. 

(c) A trained employee is an employee who has worked at the plant at least one (1) month 

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process. 

(d) On days that the NESHAP monitoring required in Condition D.3.10 is performed, the 

Permittee may use those results to satisfy the requirements of this condition for those 

facilities monitored. 

(e) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an If abnormal emissions is are observed, the Permittee 

shall take reasonable response steps in accordance with Section C - Response to 
Lehigh Cement Company Page 25 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Excursions or Exceedances or when visible emissions are observed crossing the

property line. Failure to take response steps in accordance with Section C - Compliance 

Response Plan- Preparation, Implementation, Records, and Reports Response to

Excursions or Exceedances shall be considered a violation deviation of this permit. 

D.3.12 Parametric Monitoring

The Permittee shall record the total static pressure drop across each baghouse associated with

the raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the clinker handling facilities/emission units (EU25, EU26a, 

EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/emission units (EU32

through EU36 and EU38), and the finish material storage and bulk loading and packaging 

facilities/emission units (EU37, EU39 through EU47) at least once per day when the associated 

facility/emission units are in operation and venting to the atmosphere. The Permittee shall record 

the pressure drop across all other baghouses at least once per day when the associated

facility/emission units are in operation and venting to the atmosphere. When for any one reading,

the total static pressure drop across a baghouse is outside the normal range of 1.0 and 8.0

inches of water or a range established during the latest stack test, the Permittee shall take

reasonable response steps in accordance with Section C - Compliance Response Plan -

Preparation, Implementation, Records, and Reports Response to Excursions or Exceedances. 

A pressure reading that is outside the above mentioned range is not a deviation from this permit. 

Failure to take response steps in accordance with Section C - Compliance Response Plan -

Preparation, Implementation, Records, and Reports Response to Excursions or Exceedances, 

shall be considered a violation of this permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months. 

D.3.13 Baghouse Inspections

An inspection shall be performed each calendar quarter of all bags controlling the process listed 

in this section when venting to the atmosphere. A baghouse inspection shall be performed within 

three months of redirecting vents to the atmosphere and every three months thereafter. Inspections are optional when venting to the indoors. Inspections required by this condition shall not be 

performed in consecutive months. All defective bags shall be replaced.

D.3.14 13 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the Compliance Response Plan shall be initiated. For any failure with corresponding response

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with

Section C - Compliance Response Plan - Preparation, Implementation, Records, and

Reports, shall be considered a violation of this permit. 

(b) (a) For a single compartment baghouses controlling emissions from a process operated 
Lehigh Cement Company Page 26 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

 continuously, if failure is indicated by a significant drop in the baghouse’s pressure

 readings with abnormal visible emissions or the failure is indicated by an opacity 

 violation, or if bag failure is determined by other means, such as gas temperatures, flow 

 rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the associated 

 process will shall be shut down immediately until the failed units have been repaired or 

 replaced. Operations may continue only if the event qualifies as an emergency and the 

 Permittee satisfies the requirements of the emergency provisions of this permit (Section 

 B - Emergency Provisions). 

(b) For a single compartment baghouses controlling emissions from a batch process, if 

failure is indicated by a significant drop in the baghouse’s pressure readings with 

abnormal visible emissions or the failure is indicated by an opacity violation, or if bag 

failure is determined by other means, such as gas temperatures, flow rates, air infiltration, 

leaks, dust traces, or triboflows, then the feed to the process failed units and the

associated process will shall be shut down immediately until the failed units have been 

repaired or replaced. The emissions unit shall be shut down no later than the 

completion of the processing of the material in the line. Operations may continue 

only if the event qualifies as an emergency and the Permittee satisfies the requirements 

of the emergency provisions of this permit (Section B - Emergency Provisions). 

Bag failure can be indicated by a significant drop in the baghouses pressure reading with 

abnormal visible emissions, by an opacity violation, or by other means such as gas 

temperature, flow rate, air infiltration, leaks, dust traces or triboflows. 

Record Keeping and Reporting Requirement [326 IAC 2-7-5(3)] [326 IAC 2-7-19]

D.3.15 14 Record Keeping Requirements 

(a) To document compliance with Condition D.3.11, the Permittee shall maintain records of 

visible emission notations of the baghouse stack exhausts controlling the raw mill storage 

facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer 

points associated with the clinker handling facilities/emission units (EU25, EU26a, 

EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/emission units 

(EU32 through EU36 and EU38), and the finish material storage and bulk loading and 

packaging facilities/emission units (EU37, EU39 through EU47) once per day and all 

other baghouse stack exhausts once per shift day. 

(b) To document compliance with Condition D.3.12, the Permittee shall maintain records of 

the inlet and outlet differential static pressure drop of each baghouse associated with the 

raw mill storage facilities/emissions units (EU13, EU14, EU18, EU20 and EU22), the conveyor transfer points associated with the clinker handling facilities/emission units (EU25, 

EU26a, EU26b, EU27, and EU29) the roll crusher (EU31), the finish mill facilities/ 

emission units (EU32 through EU36 and EU38), and the finish material storage and bulk 

loading and packaging facilities/emission units (EU37, EU39 through EU47) once per day 

and all other baghouses once per shift day. 

(c) To document compliance with Condition D.3.13, the Permittee shall maintain records of 

the results of the inspections required under Condition D.3.13.

(d) (c ) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall 

maintain all records required by 40 CFR 63.1355. These records include the following: 
Lehigh Cement Company Page 27 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(1) The Permittee shall maintain files of all information (including all reports and 

notifications) required by 40 CFR 63.1355(a), recorded in a form suitable and 

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

(2) The Permittee shall maintain records for each affected source as required by 40 

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

 (B) All records of applicability determination, including supporting analyses. 

(e) (d) To document compliance with Condition D.3.6(b)(5), (15), (22) and (25), the Permittee 

shall maintain records of the Finish Mill Surge Bin (EU37), the Lime Bin (EU38), the 

Railroad Loadout Bin (EU45), the Articuloader (EU46) and the Packing Machine (EU47) 

operating hours. 

(f) (e) All records shall be maintained in accordance with Section C - General Record Keeping 

Requirements, of this permit. 

 

D.3.16 15 Reporting Requirements 

No other changes. 

D.4.9 Particulate Control [326 IAC 2-7-6(6)] 

(a) Except as otherwise provided by statute, rule or this permit, the ESPs (KP1, KP2, and 

KP3) for PM control shall be in operation at all times when the associated kiln is in 

operation and control emissions, in order to demonstrate compliance with Conditions 

D.4.1 and D.4.4. 

 (b) In the event that bag failure is observed in a multi-compartment baghouse, if 

operations will continue for ten (10) days or more after the failure is observed 

before the failed units will be repaired or replaced, the Permittee shall promptly 

notify the IDEM, OAQ of the expected date the failed units will be repaired or 

replaced. The notification shall also include the status of the applicable compliance 

monitoring parameters with respect to normal, and the results of any response 

actions taken up to the time of notification. 

D.4.14 Parametric Monitoring 

(a) The ability of the ESPs to control particulate emissions shall be monitored once per shift

day when the units are in operation, by measuring and recording and comparing the total 

power of the ESP to the minimum total power of thirty-five kilowatts (35 kW). 

(b) When for any reading, the total power is below the minimum total power of 35 kW, the 

Permittee shall take reasonable response steps in accordance with Section C – 

Compliance Response Plan - Preparation, Implementation, Records, and Reports 

Response to Excursions or Exceedances. A total power reading below the minimum 

is not a deviation from this permit. 

Failure to take response steps in accordance with Section C - Compliance Response 

Plan - Preparation, Implementation, Records, and Reports Response to Excursions or

Exceedances, shall be considered a violation deviation of this permit. 
Lehigh Cement Company Page 28 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

D.4.15 Opacity Readings 

The ability of the ESP to control particulate emissions shall be monitored by continuously 

measuring and recording the opacity of emissions from each of the kiln stack exhausts (S-KP1

and S-KP2). 

(a) The opacity shall be determined by the certified continuous opacity monitor required in

Condition D.4.11. 

D.5.9 Particulate Control [326 IAC 2-7-6(6)]

(a) Except as otherwise provided by statute, rule or this permit, each baghouse (KDC2, 

KDC4 and KDC6) for PM control shall be in operation at all times when its associated

clinker cooler is in operation and control emissions, in order to demonstrate compliance

with Condition D.5.1 and D.5.4. 

D.5.11 Parametric Monitoring

The Permittee shall record the total static pressure drop across each clinker cooler baghouse 

(KDC2, KDC4 and KDC6), at least once per day when the associated facility/emissions unit is in 

operation and venting to the atmosphere. When for any one reading, the pressure drop across a

baghouse is outside the normal range of 1.0 and 8.0 inches of water or a range established 

during the latest stack test, the Permittee shall take reasonable response steps in accordance 

with Section C - Response to Excursions or Exceedances. A pressure reading that is outside the 

above mentioned range is not a deviation from this permit. Failure to take response steps in 

accordance with Section C - Response to Excursions or Exceedances, shall be considered a

deviation of this permit. 

The instrument used for determining the pressure shall comply with Section C - Pressure Gauge

and Other Instrument Specifications, of this permit, shall be subject to approval by IDEM, OAQ,

and shall be calibrated at least once every six (6) months 

D.5.12 Baghouse Inspections

An inspection shall be performed each calendar quarter of all bags controlling the process listed 

in this section when venting to the atmosphere. A baghouse inspection shall be performed within 

three months of redirecting vents to the atmosphere and every three months thereafter. Inspections are optional when venting to the indoors. Inspections required by this condition shall not be 

performed in consecutive months. All defective bags shall be replaced.

D.5.13 12 Broken or Failed Bag Detection 

In the event that bag failure has been observed. 

(a) For multi-compartment units, the affected compartments will be shut down immediately

until the failed units have been repaired or replaced. Operations may continue only if 

there are no visible emissions from the emission unit, control device, or stack, or if the 

event qualifies as an emergency and the Permittee satisfies the emergency provisions of

this permit (Section B- Emergency Provisions). Within eight (8) business hours of the

determination of failure, response steps according to the timetable described in the

Compliance Response Plan shall be initiated. For any failure with corresponding response

steps and timetable not described in the Compliance Response Plan, response steps 

shall be devised within eight (8) business hours of discovery of the failure and shall

include a timetable for completion. Failure to take response steps in accordance with
Lehigh Cement Company Page 29 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

Section C - Response to Excursions or Exceedances, shall be considered a violation of 

this permit. 

(b) (a) For a single compartment baghouses controlling emissions from a process operated

continuously, if failure is indicated by a significant drop in the baghouse’s pressure 

readings with abnormal visible emissions or the failure is indicated by an opacity

violation, or if bag failure is determined by other means, such as gas temperatures, flow

rates, air infiltration, leaks, dust traces, or triboflows, then failed units and the associated

process will shall be shut down immediately until the failed units have been repaired or

replaced. Operations may continue only if the event qualifies as an emergency and the 

Permittee satisfies the requirements of the emergency provisions of this permit (Section

B - Emergency Provisions).

(b) For a single compartment baghouses controlling emissions from a batch process, if

failure is indicated by a significant drop in the baghouse’s pressure readings with

abnormal visible emissions or the failure is indicated by an opacity violation, or if bag

failure is determined by other means, such as gas temperatures, flow rates, air infiltration, 

leaks, dust traces, or triboflows, then the feed to the process failed units and the

associated process will shall be shut down immediately until the failed units have been 

repaired or replaced. The emissions unit shall be shut down no later than the

completion of the processing of the material in the line. Operations may continue

only if the event qualifies as an emergency and the Permittee satisfies the requirements 

of the emergency provisions of this permit (Section B - Emergency Provisions).

Bag failure can be indicated by a significant drop in the baghouses pressure reading with

abnormal visible emissions, by an opacity violation, or by other means such as gas

temperature, flow rate, air infiltration, leaks, dust traces or triboflows. 

D.5.14 13 Opacity Readings 

The ability of the baghouses to control particulate emissions shall be monitored by continuously

measuring and recording the opacity of emissions from each of the clinker cooler stack exhausts 

(S-KDC2, S-KDC4, and S-KDC6). 

(a) Appropriate response steps shall be taken in accordance with Section C - Compliance 

Response Plan - Preparation, Implementation, Records, and Reports whenever the opacity

exceeds 8 percent for three (3) consecutive six (6) minute averaging periods. Failure to 

take response steps in accordance with Section C - Compliance Response Plan - Preparation, Implementation, Records, and Reports, shall be considered a violation of this 

permit.

(a) The opacity shall be determined by the certified continuous opacity monitor required in

Condition D.5.8. 

D.5.15 14 Record Keeping Requirements 

(a) To document compliance with Conditions D.5.4, D.5.6, D.5.7, and D.5.8, the Permittee 

shall maintain records in accordance with (1) and (2) below. 

(1) Data and results from the most recent stack test.

(2) All continuous emissions monitoring data. 
Lehigh Cement Company Page 30 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

(b) To document compliance with Condition D.5.11, the Permittee shall maintain records of 

the differential static pressure drop of each baghouse once per day. 

(c) To document compliance with Condition D.5.12, the Permittee shall maintain records of 

the results of the inspections required under Condition D.5.12.

(d) (c) To document compliance with the NESHAP 40 CFR 63, Subpart LLL, the Permittee shall 

maintain all records required by 40 CFR 63.1355. These records include the following: 

 (1) The Permittee shall maintain files of all information (including all reports and 

notifications) required by 40 CFR 63.1355(a) recorded in a form suitable and 

readily available for inspection and review as required by 40 CFR 63.10(b)(1). 

 (2) The Permittee shall maintain records for each affected source as required by 40 

CFR 63.10(b)(2) and (3) including: 

(A) All documentation supporting initial notifications and notifications of 

compliance status under 40 CFR 63.9. 

(B) All records of applicability determination, including supporting analyses. 

(3) The Permittee shall maintain all records of continuous monitoring system data 

required by 40 CFR 63.10(c). 

(e) (d) All records shall be maintained in accordance with Section C - General Record Keeping 

Requirements, of this permit. 

D.5.16 15 Reporting Requirements 

 No other changes. 

D.7.7 Particulate Control [326 IAC 2-7-6(6)] 

(a) In order to comply with condition D.7.3, the baghouse for particulate control shall be in 

operation and control emissions from the CKD storage silo, identified as EU48, at all 

times that the CKD storage silo is in operation. 

 (b) In the event that bag failure is observed in a multi-compartment baghouse, if 

 operations will continue for ten (10) days or more after the failure is observed before 

 the failed units will be repaired or replaced, the Permittee shall promptly notify the 

 IDEM, OAQ of the expected date the failed units will be repaired or replaced. The 

 notification shall also include the status of the applicable compliance monitoring 

 parameters with respect to normal, and the results of any response actions taken up 

 to the time of notification. 

D.7.10 Visible Emissions Notations 

 (a) Visible emission notations of the calcium sulfate material facilities/emission units, 

including the synthetic gypsum hopper (F11), synthetic gypsum weight belt (F15), raw 

material hopper (F13), raw material weight belt (F16), main belt #1 (F17), CKD storage 

silo (EU48), main belt #2 (F18), and all transfer points shall be performed once per day 

during normal daylight operations. A trained employee shall record whether emissions 

are normal or abnormal. 
Lehigh Cement Company Page 31 of 31 

Mitchell, Indiana SSM 093-21793-00002 

Permit Reviewer: Walter Habeeb SPM 093-21975-00002 

 (b) For processes operated continuously, "normal" means those conditions prevailing, or 

expected to prevail, eighty percent (80%) of the time the process is in operation, not 

counting startup or shut down time. 

 (c) In the case of batch or discontinuous operations, readings shall be taken during that part 

of the operation that would normally be expected to cause the greatest emissions. 

 (d) A trained employee is an employee who has worked at the plant at least one (1) month 

and has been trained in the appearance and characteristics of normal visible emissions 

for that specific process. 

(e) The Compliance Response Plan for these units shall contain troubleshooting contingency 

and response steps for when an If abnormal emissions is are observed, the Permittee shall 

take reasonable response steps in accordance with Section C - Response to Excursions or 

Exceedances or when visible emissions are observed crossing the property line. Failure to 

take response steps in accordance with Section C - Compliance Response PlanPreparation, Implementation, Records, and Reports Response to Excursions or 

Exceedances shall be considered a violation deviation of this permit. 

D.7.11 Record Keeping Requirements [326 IAC 20-27] [40 CFR 63.1355]

(c) To document compliance with Condition D.7.5, the Permittee shall maintain records of 

any additional inspections prescribed by the Preventive Maintenance Plan.

(d c) To document compliance with Condition D.7.10, the Permittee shall maintain records of 

visible emission notations of the calcium sulfate material facilities/emission units, 

including the synthetic gypsum hopper (F11), synthetic gypsum weight belt (F15), raw 

material hopper (F13), raw material weight belt (F16), main belt #1 (F17), CKD storage 

silo (EU48), main belt #2 (F18), and all transfer points once per day. 

(e d) All records shall be maintained in accordance with Section C - General Record Keeping 

Requirements, of this permit. 

Conclusion

This proposed modification shall be subject to the conditions of the attached proposed Part 70 

Significant Source Modification No. 093-21793-00002 and Significant Permit Modification No. 

093-21975-00002. 
Attachment A1 

Ms. Debbie Tolliver 

Lehigh Cement Company 

121 North First Street 

P.O. Box 97 

Mitchell, Indiana 47446 

 Re: 093-21975-00002 

 Significant Permit Modification to 

 Part 70 No.: T093- 5990-00002 

Dear Ms. Tolliver: 

 Lehigh Cement Company, located at 121 North First Street, Mitchell, Indiana 47446 was 

issued a Part 70 permit on December 30, 2002 for a portland cement manufacturing plant. A 

letter requesting changes to this permit was received on September 13, 2005. Lehigh requested 

its Part 70 Operating Permit be modified to allow the burning of coal and treated wood blends in 

Kiln #1 and Kiln #2. Lehigh’s application also included the request to utilize the Kiln #1 and Kiln 

#2 alternative fuel delivery systems (F19 and F20) to deliver the treated wood to Kilns #1 and Kiln 

#2. 

Pursuant to the provisions of 326 IAC 2-7-12 a significant permit modification to this 

permit is hereby approved. 

Part 70 Operating Permit No. 093-5990-00002 has been modified to: 

1. Include that Kiln #1 and Kiln #2 are each permitted to burn a blended fuel of coal 

and clean and/or treated wood where the blend has a maximum of 35% clean 

and/or treated wood by heat input in the facility descriptions in Section A.2(ccc) 

and (ddd), and in Section D.4; 

2. Amend IDEM’s address in Sections B.10(a), B.11(a), B.12(b)(5), B.15(b), 

B.17(a), B.18(b), B.20(a)(4), B.23(b), C.8(d), C.9(a), C.11, C.19(b), C.21(b), 

C.22(f), and on the Emergency Occurrence Report Form; 

3. Incorporate the credible evidence requirements of 326 IAC 1-1-6 into Condition 

B.25 and in the Table of Contents; 

4. Incorporate the 326 IAC 2-2-8(b) and (c) New Source Review record keeping and 

reporting requirements in Conditions C.20 and C.21 and in the Table of Contents; 

5. Correct the reference to the citation “40 CFR 63.1349(b)(2)” in Condition 

D.2.9(c); 

6. Clarify the NESHAP requirements in Condition D.2.11(a) consistent with 40 CFR 

§ 63.1350; and 

7. Include in Condition D.4.1.1 that Kiln #1 and Kiln #2 are both permitted to burn a 

blended fuel of coal and treated wood where the blend has a maximum of up to 

35% clean and/or treated wood by heat input. 

Other than the permit modifications detailed in this approval letter, all other 

conditions/requirements of Lehigh Cement Company’s Part 70 Operating Permit shall remain 

unchanged and unaffected. Please find enclosed a reprinted copy of the entire Part 70 Operating 

Permit. 
Lehigh Cement Company Page 2 of 2 

Mitchell, Indiana TSD Addendum – Attachment A1 

This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-

21.5-3-5. If you have any questions on this matter, please contact Walter Habeeb OAQ, 100 

North Senate Avenue, Indianapolis, Indiana, 46204, or call at (800) 451-6027, and ask for Walter 

Habeeb or extension (2-8422), or dial (317) 232-8422. 

 

 Sincerely, 

 Nisha Sizemore, Chief 

 Permit Branch 

 Office of Air Quality 

Attachments 

WH 

cc: File - Lawrence County 

 U.S. EPA, Region V 

 Lawrence County Health Department 
Ms. Debbie Tolliver 

Lehigh Cement Company Attachment B1

121 North First Street 

P.O. Box 97 

Mitchell, Indiana 47446 

 Re: 093-21793-00002 

 Significant Source Modification to 

 Part 70 No.: T093- 5990-00002 

Dear Ms. Tolliver: 

 Lehigh Cement Company, located at 121 North First Street, Mitchell, Indiana 47446 was 

issued a Part 70 permit on December 30, 2002 for a portland cement manufacturing plant. A 

letter requesting changes to this permit was received on September 13, 2005. Pursuant to 326 

IAC 2-7-10.5 the modification request to allow the burning of coal and treated wood blends in Kiln 

#1 and Kiln #2, and to utilize the Kiln #1 and Kiln #2 alternative fuel delivery systems (F19 and 

F20) to deliver the treated wood to Kiln #1 and Kiln #2 is approved. 

 

 Although the modification does not involve any construction, the modification is subject to 

326 IAC 2-7-10.5 because the modification has the potential to emit greater than or equal to ten 

(10) tons per year of a single hazardous air pollutant or twenty-five (25) tons per year of any 

combination of hazardous air pollutants. 

 The following conditions are applicable to the source modification: 

1. The data and information supplied with the application shall be considered part of this 

source modification approval. Prior to any proposed change which may affect the 

potential to emit (PTE) of the proposed project, the change must be approved by the 

Office of Air Quality (OAQ). 

 

2. This approval does not relieve the permittee of the responsibility to comply with the 

provisions of the Indiana Environmental Management Law (IC 13-11 through 13-20; 13-

22 through 13-25; and 13-30), the Air Pollution Control Law (IC 13-17) and the rules 

promulgated thereunder, as well as other applicable local, state, and federal 

requirements. 

3. Effective Date of the Permit

 Pursuant to IC 13-15-5-3, this approval becomes effective upon its issuance. 

4. All requirements and conditions of this source modification approval shall remain in effect 

unless modified in a manner consistent with procedures established pursuant to 326 IAC 

2. 

 

6. Pursuant to 326 IAC 2-7-10.5(g)(4)(C), operation of this modification is not approved until 

the Significant Permit Modification has been issued. 

 This decision is subject to the Indiana Administrative Orders and Procedures Act - IC 4-

21.5-3-5. If you have any questions on this matter call (800) 451-6027, and ask for Walter 

Habeeb or extension (2-8422), or dial (317) 232-8422. 
 Sincerely, 

 Nisha Sizemore, Chief 

 Permits Branch 

 Office of Air Quality 

Attachments 

WVH 

cc: File - Lawrence County 

 Lawrence County Health Department 

 Air Compliance Section Inspector – Ray Schick 

 Compliance Data Section 

 Administrative and Development 
 

 Appendix A: Emissions Calculations Page 1 of 1 

 Company Name: Lehigh Cement Company 

 Address: 121 North First Street, Mitchell, Indiana 47446 

 Permit Number: 093-21975-00002 & 093-21793-00002 

 Reviewer: Walter Habeeb 

 Date: October 14, 2005 

 

 NSR Project Evaluation (tpy) * 

 CO NOx SO2 VOC PM PM10 Pb HAPs 

Adjusted 

Baseline Actual 

Emissions 

395.59 2,638.79 1,778.93 63.96 66.33 139.76 0.01671 13.20 

Projected 

Actual 

Emissions 

486.03 1,482.23 1,340.61 9.66 55.78 74.53 0.02253 17.78 

Net Emissions 90.44 -1,156.56 -438.32 -54.30 -10.55 -65.23 0.00582 4.58 

PSD Threshold 

Level 

 100 40 40 40 25 15 0.60 10 

single 

25 all 

* Emissions provided by the source and based on adjusted baseline actual emissions for CO, 

 NOx, SO2, VOC, PM and PM10 for time period April 1998 through March 2000. 

 Adjusted baseline actual emissions for Pb is based on time period August 2003 through July 

 2005. Adjusted baseline actual emissions for HAPs are based on the time period July 2003 

 through June 2005. 

 Potential to Emit (tpy) * 

 CO NOx SO2 VOC PM PM10 Pb HAPs 

Potential to Emit 

before 

Modification (tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54397 18.32 

Potential to Emit 

after Modification 

(tpy) 

537.53 3,585.69 2,417.28 96.56 91.18 190.41 0.54396 18.32 

Net Emission 

Increase (tpy) 

 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 

*Emissions provided by the source. Before modification emissions based on Part 70 

 Operating Permit limits. After modification (alternative fuel delivery system) emissions 

 based on AP-42 Section 13.2.4.